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TCFD – The UK’s Roadmap to Mandatory Climate-related Disclosures



Speaking at the Green Horizon Summit, on the 9th of November, the Financial Conduct Authority (FCA) outlined tighter rules on climate risk reporting in line with recommendations from the Taskforce on Climate-related Financial Disclosures (TCFD).


It was announced that all publicly listed UK companies with a premium listing will be required to report in line with the TCFD requirements in the form of a “comply or explain” approach, by 2023. These rules will be extended and further tightened following further consultation in 2025.


What is the TCFD


The TCFD was created to deliver a set of consistent comparable disclosures that companies can use to display their climate change resilience to investors and capital providers.


Unlike other reporting tools, the TCFD does not assess a company’s impact on the environment, but rather it assesses the environments impact on a company. These disclosures are aimed at ensuring climate risk is properly priced into company valuations.


What does it cover?


The TCFD recommendations covers four disclosure areas which should be included in a company’s annual financial findings.

  • Governance – the organisations governance around climate-related risk and opportunities

  • Strategy – the potential and realised impacts of climate-related risks and opportunities on the organisation’s businesses, strategy, and financial planning

  • Risk Management – the organisation’s process to identify, analyse and manage climate-related risk

  • Metrics and Targets – what an organisation uses to assess and manage climate-related risk and opportunities


For who and when?


The UK Taskforce has created a roadmap that will guide a pathway to mandatory disclosure over the next 5 years. Most action is likely to take place within the first 3 years.


This roadmap, displayed in Figure 2., illustrates how new regulatory and legislative measures could increases the coverage of TCFD over the next few years within seven categories of organisations:

  1. Listed commercial companies

  2. UK-registered large private companies

  3. Banks and building societies

  4. Insurance companies

  5. Asset Managers

  6. Life insurers and FCA-regulated pension schemes

  7. Occupational pension schemes


Next Steps


The pathway provides clarity to organisations in each of the seven categories over their potential future obligations.


Comparability between disclosures is essential, and as such, a more detailed list of expectations for disclosures is anticipated moving forward.


Preparing for TCFD


To prepare for mandatory TCFD disclosures organisations need to understand the implications specific to them. This includes:

  • Conducting a gap analysis to understand what is already being disclosed vs what is required.

  • Identifying missing data gaps and processes.

  • Reviewing scenario analysis and incorporate appropriate scenarios across the value chain

  • And integrating climate change into governance process.


*Note – overlaps exist between certain groups within the seven categories shown below.

Figure 2. Roadmaps towards mandatory TCFD-aligned disclosures for each category organisation



If you’d like to discuss the implications of climate-related disclosures further, please get in touch.



About Us

Governex is an ESG advisory business that helps businesses with corporate governance as well as answering the question of how they make positive contribution to the environment and social issues.

We help organisations implement the right shift in focus from a purely financial commitment to include environmental, social and governance commitments. All in the context of meeting business purpose, strategy, integrity and diversity.



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0131 261 6630

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  • Governex Limited

©Governex 2020.

Governex is a trading name of Governex Limited a private company registered in Scotland with company number SC654245.

Registered office Summit House, 4 - 5 Mitchell Street, Edinburgh, United Kingdom, EH6 7BD