Who does this affect: Standard listed issuers as well as asset managers and FCA-regulated asset owners.
Why has it been introduced: The FCA expressed concern that the current quantity and quality of climate-related financial disclosure were not meeting investors’ needs. The FCA prioritized enhancing climate-related disclosures in recognition that climate is a relevant consideration for all companies and a likely material one for most.
What does it require: Largely TCFD-based disclosures, including GHG emissions, on a ‘comply or explain’ basis. As of March 2023, the U.K. has stated their intention to assess the International Sustainability Standards Board’s climate and sustainability-related disclosure standards for potential adoption when they are published later in 2023.
When did these rules come into effect: The most recent rule expanding the scope of companies covered came into effect in April 2022.
Where is reporting required: Annual financial reporting preferred. If disclosures are included in a document other than the annual financial report, companies must provide information on why this is the case and where the climate-related disclosures can be found.
Original text: FCA ‘Enhancing climate-related disclosures by standard listed companies’ Policy Statement December 2021, FCA ‘Enhancing climate-related disclosure by asset managers, life insurers, and FCA-regulated pension providers,’ FCA ‘Our climate-related financial disclosure 2021/22’
Who does this affect: PPN 06/21 applies to all Central Government Departments, their Executive Agencies, and Non-Departmental Public Bodies (NDPBs). The suppliers of these affected bodies with a value of over £5 million per year for goods or services, or £35 million for works are also affected by proxy.
Why has it been introduced: To support the UK government's commitment to achieving net-zero carbon emissions by 2050, as part of its efforts to address the climate crisis.
What does it require: Affected bodies are to include a requirement for bidding suppliers to provide a Carbon Reduction Plan and environmental management measure in place that will be in effect during the performance of the contract in order to ensure alignment with the UK Net Zero by 2050 initiative. Carbon Reduction Plans are required to include the following information:
When did this policy come into effect: This policy came into effect in August 2021 and applies to all major government contracts that were advertised on or after September 30th 2021.
Where is reporting required: The Carbon Reduction Plan is to be published on the suppliers website.
Original text: ‘Procurement Policy Note – Taking Account of Carbon Reduction Plans in the procurement of major government contracts,’ ‘Guidance on adopting and applying PPN 06/21,’ and ‘Technical standard for completion of Carbon Reduction Plans’
Who does this affect: All quoted UK companies of any size listed on the London Stock Exchange, a European Economic Area state, NASDAQ or the New York Stock Exchange. Large unquoted companies incorporated in the U.K., including charitable companies, and large limited liability partnerships (LLPs) are also affected.
Why was it introduced: To promote transparent, modernized carbon and energy reporting that reduces reporting burdens, improves the quality of reported information, and encourages improved energy efficiency for UK companies.
What does it require: Information on energy usage (gas, purchased electricity, and transport fuel), GHG emissions (reported in tonnes of carbon dioxide equivalent), calculation methodology, an intensity ratio comparing emissions to a business metric, narrative description of energy efficiency improvement efforts, and how the information reported compares to the previous year’s data.
When did this regulation come into effect: SECR was implemented on April 1, 2019 after being introduced the year before.
Where is reporting required: Information should be included in the companies’ Directors’ Report or similar energy and carbon report. These are to be filed with the Companies House. Businesses that embed SECR within the company strategy can also include this information in strategic reports while also explaining this in the Directors’ Report. LLPs need to file a separate energy and company report to the Companies House.
Official text: Environmental Reporting Guidelines: Including streamlined energy and carbon reporting guidance
Additional resources:
Who does this affect: Once finalized, the TPT Disclosure Framework will be available for corporations and regulators across the world to use on a voluntary basis. The TPT Disclosure Framework is a set of best practices for the creation and disclosure of transition plans. Transition plans are documents prepared by companies that describe how those companies will achieve their climate targets. The TPT Disclosure Framework does not bind any particular company or jurisdiction. Instead, it supports regulators in drafting guidance for transition plans, with a specific focus on informing UK regulators.
Why has it been introduced: The TPT Disclosure Framework aims to ensure that transition plans are credible and comparable, with the ultimate goals of providing investors with information to make financial decisions, ensuring companies have the right guidance to develop transition plans, and supporting jurisdictions in their net zero commitments
What does it recommend:
The TPT recommends reporting on transition plans across five areas: (1) Foundation, including objectives and priorities; (2) Implementation strategy; (3) Engagement strategy; (4) Metrics and targets; (5) Governance.
The TPT guidance pushes for detailed disclosures to give observers an accurate sense of the maturity of a company’s transition plan. For example, Sub-Element 2.1 of the November 2022 publication asks companies to “[d]isclose the roadmap of short-, medium- and long-term actions the entity will take to deliver on the strategic ambition in its transition plan and achieve its stated objectives and priorities[...].”
When are these standards being developed: The TPT launched in April 2022 with a 2-year mandate to develop best practices for transition planning.
Where is reporting suggested: The TPT recommends reporting in two places. First, they recommend including material information about the company’s transition plan in its financial report. Second they recommend a standalone transition plan document.
Original Text: Publications - Transition Taskforce
Who does this affect: Once developed, the standards are intended to apply to UK registered companies and limited liability partnerships, and FCA-regulated UK listed companies.
Why are these standards being introduced: In 2023, the UK government announced its plans to create UK Sustainability Disclosure Standards based on the IFRS Sustainability Disclosure Standards issued by the ISSB. The new UK Sustainability Disclosure Standards will form the basis of any future requirements in UK legislation or regulation for companies reporting on sustainability and climate-related risks and opportunities.
What does it require: While they are not finalized, we know that the ISSB Standards require entities to disclose sustainability-related and climate-related information on governance, risk and opportunity management, strategy, and related metrics and targets. They aim to provide investors and other stakeholders with comprehensive, globally comparable information on sustainability risks and opportunities. The UK government clearly stated that the Sustainability Disclosure Standards will divert from the ISSB's global baseline standards only "if absolutely necessary for UK-specific matters."
When will these standards be issued: The UK government has committed to issuing its endorsement decision of the ISSB standards by July 2024. The UK FCA will likely move to update its listing standards as soon as these UK incorporation processes are complete. The UK government will then also take steps to use the UK Sustainability Disclosure Standards for disclosures by UK-registered companies and limited liability partnerships.
Original text: Guidance: UK Sustainability Disclosure Standards
Additional Resources: