For periods commencing on or after 1 January 2021, premium-listed commercial companies (including sovereign-controlled commercial companies) are required to include a statement in their annual financial report setting out:

• Whether they have made disclosures consistent with the Task Force on Climate-related Financial Disclosures (TCFD’s) recommendations and recommended disclosures in their annual financial report.
• Where they have not made disclosures consistent with some or all of the TCFD’s recommendations and/or recommended disclosures, an explanation of why, and a description of any steps they are taking or plan to take to be able to make consistent disclosures in the future – including relevant timeframes for being able to make those disclosures.
• Where they have included some, or all, of their disclosures in a document other than their annual financial report, an explanation of why.
• Where in their annual financial report (or other relevant document) the various disclosures can be found.

The rule is accompanied by guidance to help listed companies determine whether their disclosures are consistent with the TCFD’s recommendations and recommended disclosures. The guidance also clarifies the limited circumstances in which the FCA would expect in-scope companies to explain rather than disclose.

The FCA is extending these requirements to standard-listed companies, asset managers, life insurers and FCA-regulated pension providers for periods commencing on or after 1 January 2022. 

The Department for Business, Energy and Industrial Strategy (BEIS) has laid draft legislation requiring mandatory climate-related disclosures for UK public interest entities (UK PIEs), AIM companies, “high turnover” companies and LLPs (“high turnover” is defined as turnover of more than £500m per annum, pro-rated for shorter or longer periods). Companies and LLPs with fewer than 500 employees will be exempt. These requirements will take effect for periods commencing on or after 6 April 2022. The required disclosures are similar to the TCFD recommendations and will be accompanied by non-binding guidelines to assist in implementation.

The FRC has stated that it will pay particular focus on the quality of disclosures made by premium-listed companies against the new Listing Rule. Likewise, the FCA has stated in its recently issued Primary Market Bulletin 36 that it will work collaboratively with the FRC to identify instances of non-compliance, including reporting such instances to one another where discovered, and review concerns raised by stakeholders about the quality of TCFD-aligned disclosures.

Where a premium-listed company fails to make a suitable statement under the Listing Rules, the FCA will request that a listed company publishes the TCFD statement via a Regulatory Information Service (RIS) in line with the Listing Rules as soon as possible after discovery, with any non-compliance leading to regulatory action and possible sanctions.

This page includes a collection of our publications on the new TCFD listing rule and scope extension.