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    TCFD explained: the 4 pillars, 11 disclosures and UK TCFD reporting requirements in 2026

    TCFD is the Task Force on Climate-related Financial Disclosures framework: four pillars (governance, strategy, risk management, metrics and targets) and 11 recommended disclosures. In the UK it underpins the FCA listing rules and the Companies Act climate disclosure rules. For listed companies, UK SRS replaces the TCFD-aligned rule for periods from 1 January 2027.

    Last updated 4 November 2026 · By Ella Sustainability Team

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    What is TCFD?

    The Task Force on Climate-related Financial Disclosures was set up by the Financial Stability Board in 2015 and published its recommendations in 2017. The aim was simple: give investors, lenders and insurers consistent information about how climate change affects a company's finances. The recommendations are built around four pillars that mirror how a business is run: governance, strategy, risk management, and metrics and targets. Under those pillars sit 11 recommended disclosures. TCFD is a disclosure framework. It asks you to report Scope 1, Scope 2 and, where appropriate, Scope 3 emissions, and leaves the calculation method to the GHG Protocol. That matters in practice, because the emissions numbers are usually where a TCFD report gets stuck.

    The 4 TCFD pillars and 11 recommended disclosures

    These are the 11 disclosures as the Task Force set them out, with a plain-English note on what each one usually means for a sustainability team.
    The 4 TCFD pillars and 11 recommended disclosures
    PillarRecommended disclosureWhat it means in practice
    Governancea. The board's oversight of climate-related risks and opportunitiesWhich board or committee reviews climate, how often, and what it has decided
    Governanceb. Management's role in assessing and managing climate-related risks and opportunitiesNamed roles, reporting lines and how climate reaches the executive team
    Strategya. Climate-related risks and opportunities over the short, medium and long termA short list of material risks and opportunities with the time horizons you use
    Strategyb. Impact on the business, strategy and financial planningWhere those risks show up in revenue, costs, capital spend or financing
    Strategyc. Resilience of the strategy under different climate scenarios, including a 2°C or lower scenarioScenario analysis, qualitative at first for most companies
    Risk managementa. Processes for identifying and assessing climate-related risksHow climate risks are found and scored
    Risk managementb. Processes for managing climate-related risksWho owns each risk and what mitigation is in place
    Risk managementc. Integration into overall risk managementClimate risks held in the main company risk register
    Metrics and targetsa. Metrics used to assess climate-related risks and opportunitiesEnergy use, carbon intensity and other KPIs you actually track
    Metrics and targetsb. Scope 1, Scope 2 and, if appropriate, Scope 3 emissions and related risksA GHG inventory with a clear method and data sources
    Metrics and targetsc. Targets used to manage climate-related risks and performance against themReduction targets, base year and progress each year

    Is TCFD still relevant now the Task Force has disbanded?

    Yes, for now. The TCFD released its final status report on 12 October 2023 and disbanded, having fulfilled its remit. The Financial Stability Board asked the IFRS Foundation to take over monitoring of companies' climate-related disclosures from 2024. The recommendations live on inside the ISSB standards. The IFRS Foundation says companies applying IFRS S1 and IFRS S2 will meet the TCFD recommendations, because the recommendations are fully incorporated into the ISSB standards. IFRS S2 adds more on top, including industry-based metrics, planned use of carbon credits and more detail on financed emissions. So TCFD has become a floor. UK law still refers to its structure, and many lenders, customers and CDP-style questionnaires still ask for it, but the direction of travel is towards IFRS S2 and, in the UK, the UK Sustainability Reporting Standards (UK SRS).

    Who has to report TCFD in the UK?

    Two separate UK regimes are built on TCFD. One sits in the FCA's listing rules, the other in the Companies Act. A company can fall under both.
    Who has to report TCFD in the UK?
    RegimeWho is in scopeApplies fromWhat happens next
    FCA UK Listing Rules (TCFD-aligned, comply or explain)Commercial companies with listed equity, plus some other listed issuersIntroduced for premium-listed companies in 2020 and extended to other listed issuers in 2021Replaced by UK SRS for accounting periods beginning on or after 1 January 2027 (FCA PS26/19)
    Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022Traded companies, banks and insurers with more than 500 employees; AIM companies with more than 500 employees; other UK companies with more than 500 employees and turnover over £500mFinancial years starting on or after 6 April 2022Still in force; the government's Modernising Corporate Reporting consultation closes on 30 November 2026
    Limited Liability Partnerships (Climate-related Financial Disclosure) Regulations 2022Large LLPs with more than 500 employees and turnover over £500m; traded or banking LLPs with more than 500 employeesFinancial years starting on or after 6 April 2022Still in force

    Companies Act climate disclosures: the 8 required items

    The Companies Act rules are often called mandatory TCFD, although they are written slightly differently. In-scope companies report eight items in the non-financial and sustainability information statement of their strategic report: 1. Governance arrangements for assessing and managing climate-related risks and opportunities 2. How the company identifies, assesses and manages climate-related risks and opportunities 3. How those processes are integrated into overall risk management 4. The principal climate-related risks and opportunities and the time periods used to assess them 5. The actual and potential impacts of those risks and opportunities on the business model and strategy 6. An analysis of the resilience of the business model and strategy under different climate-related scenarios 7. The targets used to manage climate-related risks and realise opportunities, and performance against them 8. The key performance indicators used to assess progress against those targets, with a description of how they are calculated Groups report at group level, so subsidiaries included in a compliant UK parent's consolidated report do not report separately. Unlike the listing rule, this regime does not spell out Scope 1, 2 and 3 emissions as a TCFD-style metric, but most companies in scope already report energy and emissions under SECR, and the KPIs in item 8 usually draw on the same data.

    What replaces TCFD for UK listed companies?

    On 30 September 2026 the FCA published Policy Statement PS26/19. It replaces the TCFD-aligned listing rule with disclosures against UK SRS S1 and S2 for accounting periods beginning on or after 1 January 2027, so the first reports land in 2028 annual reports. The related TCFD guidance is being withdrawn.
    What replaces TCFD for UK listed companies?
    PointTCFD-aligned listing rule (today)UK SRS listing rule (from 2027)
    FrameworkTCFD recommendations and 11 disclosuresUK SRS S1 (general) and S2 (climate), based on ISSB
    BasisComply or explainComply or explain on every UK SRS requirement, including Scope 3
    Scope 3Disclose if appropriateRequired under S2, with a one-year relief in the first reporting year
    Topics beyond climateNot requiredS1 covers all sustainability topics, with a two-year climate-first relief
    Transition planNot required as a separate statementMust state whether a climate transition plan has been published
    AssuranceNot requiredMust state whether external assurance was obtained
    Who is in scopeCommercial companies and certain other listed issuersThe same issuers, with no size threshold

    How to prepare a TCFD report, step by step

    Whether you are writing your first TCFD report or getting ready for UK SRS, the order of work is the same. 1. Confirm which regimes apply: the listing rule, the Companies Act rules, LLP rules, or a customer or lender request. 2. Agree governance first: which committee owns climate, how often it meets and who reports to it. 3. Build the emissions inventory: Scope 1 and 2 from energy and fuel data, then the Scope 3 categories that matter most. 4. Run a risk and opportunity workshop and score each item against your existing risk framework. 5. Do scenario analysis, starting qualitative, with at least a 2°C or lower scenario and a higher-warming scenario. 6. Set or confirm targets and the KPIs that track them, with a base year and method. 7. Draft the disclosure against each of the 11 recommendations (or the 8 Companies Act items), and explain any gaps. 8. Keep a source behind every number so finance, auditors and the board can check it. Steps 3 and 6 take the longest, because they depend on data held by facilities, finance, fleet and procurement teams. Our guides to Scope 3 categories and SECR reporting, linked below, cover that data in more depth.

    Our view: the narrative is the easy part

    Most TCFD reports we read are strong on governance and scenario narrative and weak on the numbers underneath. That is the wrong way round for what is coming. UK SRS S2 asks for Scope 3 in every case after the first-year relief, and it asks on a comply or explain basis, which means an explanation is visible to every investor who reads the annual report. On our calls, the pattern is consistent. A sustainability lead, often a team of one, works for a business that has grown quickly, sometimes through several acquisitions in a single year. Each new entity has its own energy contracts, its own expense system and its own idea of what counts as business travel. The disclosure can be drafted in a week. Getting 12 months of clean, consistent data from every entity takes months. Our advice is to work back from your first reporting year. If your first UK SRS period starts on 1 January 2027, the data for that year needs collecting through 2027. Leaving it to the weeks before the 2028 annual report is how explanations end up in print. If you also fall under ESOS, the same energy data serves both, which our ESOS guide explains.

    How Ella helps with TCFD and UK SRS reporting

    Ella is AI-native ESG reporting software and carbon accounting software, built as an agent. It handles the part of TCFD that takes the longest: getting the data in. - Collect links go to every data owner across your entities, Ella chases them and tracks missing responses - Drag-and-drop bills, receipts and spend exports, plus integrations and surveys - Boundaries set from how your business operates, with a Scope 1 to 3 checklist built instantly - Activity and spend-based emissions calculated automatically, with a source on every number - SECR summaries, reduction and net zero roadmaps and an audit trail, backed by expert support from Ella's team The result is a TCFD or UK SRS disclosure your finance team and auditors can check line by line.

    How Ella helps

    ESG reporting software

    Map your data to TCFD, UK SRS, CDP and VSME with a source on every number.

    Carbon accounting software

    Scope 1 to 3 emissions calculated automatically, with SECR summaries and an audit trail.

    ESG strategy software

    Turn climate risks and targets into a reduction and net zero roadmap your board can track.

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    Frequently Asked Questions

    What is TCFD in simple terms?

    TCFD is a framework for telling investors how climate change affects your business. It asks for disclosures under four pillars: governance, strategy, risk management, and metrics and targets, with 11 recommended disclosures in total.

    What are the 4 pillars of TCFD?

    Governance, strategy, risk management, and metrics and targets. Governance has two recommended disclosures and each of the other three pillars has three, which gives the 11 recommended disclosures companies report against.

    Is TCFD mandatory in the UK?

    Yes, for some companies. Listed commercial companies report against TCFD on a comply or explain basis under the FCA listing rules, and large companies and LLPs with more than 500 employees report similar climate disclosures under the Companies Act rules for financial years starting on or after 6 April 2022.

    Has TCFD been replaced?

    The Task Force disbanded in October 2023 and the IFRS Foundation took over monitoring. Its recommendations are fully incorporated into IFRS S2. For UK listed companies, the FCA's PS26/19 replaces the TCFD-aligned listing rule with UK SRS for periods beginning on or after 1 January 2027.

    What is the difference between TCFD and IFRS S2?

    IFRS S2 is built on the TCFD structure and meets all 11 recommendations, but it goes further. It adds industry-based metrics, information on planned use of carbon credits and more detail on financed emissions, and it requires Scope 3 emissions rather than asking for them only where appropriate.

    Do private companies have to report TCFD?

    Large private companies can. UK companies with more than 500 employees and turnover over £500m fall under the Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022, which require eight TCFD-style climate disclosures in the strategic report.

    Does TCFD require Scope 3 emissions?

    TCFD asks for Scope 1 and Scope 2, and Scope 3 if appropriate. UK SRS S2, which replaces the TCFD-aligned listing rule from 2027, requires Scope 3, with a one-year relief in the first reporting year and a comply or explain basis throughout.

    What software helps with TCFD reporting?

    Look for ESG reporting software that collects energy, fuel and spend data from every entity, calculates Scope 1 to 3 emissions with a clear audit trail and maps the results to the TCFD disclosures. Ella does this as an AI agent, chasing data owners and keeping a source on every number.

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