Deloitte comment letter on the Transition Plan Taskforce consultation on private sector transition plans

Published on: 08 Mar, 2023

We have responded to the Transition Plan Taskforce’s (TPT's) consultation on the proposed Disclosure Framework and Implementation Guidance.

We support the valuable and timely work being carried out by the TPT. High quality transition plan disclosures will play an important role in enabling investors and other stakeholders to assess companies’ progress and performance against their climate-related commitments.

In line with our response to the TPT’s Call for Evidence in 2022, we reiterate the value of guidance on how to develop a high-quality transition plan and believe the Implementation Guidance could go significantly further in supporting companies if its primary focus was on how to put in place a credible transition plan, rather than how to implement disclosure requirements.

We strongly support adoption of the International Sustainability Standards Board’s (ISSB) sustainability standards in the UK as a critical step towards achieving a global baseline of sustainability information. We note that while the Framework is consistent in purpose with the Task Force on Climate-related Financial Disclosures (TCFD) and ISSB proposed standards, it is not fully aligned. Given the UK Government’s intention to endorse the ISSB’s new sustainability standards (expected to be published in final form before the end of June 2023), we strongly encourage the TPT to fully adopt the ISSB definitions and relevant disclosure requirements with any further disclosures that are deemed necessary to meet the UK’s ambition for the gold standard of reporting on transition plans, clearly signposted as an add-on to the ISSB baseline.

Finally, we encourage TPT to engage with legislators and regulators on how the TPT disclosures are brought into the UK regulatory framework. We recommend that any legal requirements are narrowly defined with the ISSB standards identified as the applicable reporting standards and the TPT Disclosure Framework as additional application guidance on how to report with sufficient granularity. This approach would provide the flexibility necessary to allow companies to develop transition plans while learning from good practice, and to introduce the TPT disclosure recommendations more formally over time. 


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