What UK SRS S2 Requires
There is no requirement in the UK to have a climate transition plan.
UK SRS S2 requires a company that has published a transition plan to disclose information about it; it does not require a company to produce one.
Under the FCA proposals in CP26/5 — a consultation, not rules in force — in-scope listed companies would state whether they have published a transition plan and where it can be found.
If a company has not published a transition plan, it would explain why.
This is a disclose-or-explain approach to transition plans, rather than a mandate to produce one.
The FCA is not proposing UK SRS-aligned disclosures, including for transition plans, for the secondary listing and depositary receipt categories.
The requirement sits within the broader UK SRS S2 climate disclosure framework.
Where a transition plan exists, the disclosure must cover the company's emissions reduction targets (including whether they are absolute or intensity-based), the actions being taken to achieve those targets, the capital allocation committed to transition activities, and progress made against previous disclosures.
The plan must be consistent with the company's overall 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.
The TPT Framework
The UK Transition Plan Taskforce (TPT) published its Disclosure Framework in October 2023, setting out what a credible transition plan should contain.
The TPT itself has been wound down: the IFRS Foundation assumed responsibility for the TPT materials in 2024, and the IFRS Foundation (not the ISSB, and not an ISSB Standard) published guidance on disclosing transition-plan information under IFRS S2 in June 2025.
While the TPT Framework is not legally mandated under UK SRS, it is the most widely referenced guidance in the UK market and is expected to inform both corporate practice and regulatory expectations.
The framework covers five elements: foundations (company-wide ambition and governance), implementation strategy (actions and policies), engagement strategy (value chain and industry collaboration), metrics and targets, and governance.
Boards should ensure they understand the TPT Framework when overseeing transition plan development.
The Separate Government Consultation
DESNZ consulted on Climate-related transition plan requirements: implementation routes from 25 June 2025 to 17 September 2025, covering four dimensions: designing a plan, disclosing it, alignment with climate ambition, and implementing it.
The consultation has closed and no government response has been published.
The GOV.UK page status is still "We are analysing your feedback".
Nothing has therefore been decided about whether UK companies will be required to produce a transition plan, what such a plan would have to contain, or when any requirement would begin.
See regulatory updates for the latest position.
Private companies should monitor the response, since any future requirement could extend beyond listed entities — but no proposal to that effect has been published.
As KPMG's analysis of FCA CP26/5 notes, the relationship between UK SRS transition plan disclosures and any future mandatory requirements will be a key design challenge for regulators.
Any claim that transition plan obligations are certain to increase is commentary rather than published policy.
Assurance Considerations
Transition plan disclosures made within the Strategic Report under UK SRS S2 will be subject to the same assurance framework as other UK SRS disclosures.
The FRC has been tasked with establishing an interim register of sustainability assurance practitioners, targeted to be operational by mid-2026 but not yet confirmed as launched, and ISSA (UK) 5000 provides the assurance standard for engagements that are commissioned.
While assurance of transition plan disclosures is not yet mandated, audit committees should consider whether voluntary assurance would strengthen the credibility of their transition plan disclosure.
See the UK SRS mandatory timeline for all key dates.
Companies in scope should ensure their transition plan disclosures are consistent with their scenario analysis outputs and aligned with the GHG Protocol methodology used for emissions reporting.
The transition from TCFD to UK SRS represents an opportunity to strengthen transition plan disclosures.
A gap analysis can help identify where existing transition plan documentation falls short of UK SRS expectations.
For further professional guidance, see BDO's overview of sustainability reporting requirements.