UKLR 6.6.6R(8)(e) · UK SRS S2 ¶14
The UK SRS transition plan statement: a sentence, not a plan
The FCA’s UK SRS rules ask listed companies to say whether they have published a climate transition plan.
They do not ask anyone to have one, and neither does UK SRS S2.
This page separates three things that are often run together: the plan, what S2 asks about a plan, and the statement the listing rule asks for.
Three different things
The plan, the S2 disclosure, and the statement
The plan is a strategy document, and nothing in UK law makes a listed company write one.
UK SRS S2 asks what the company is doing about climate risk, and if a plan exists, ¶14(a)(iv) asks about it.
The listing rule asks a narrower question still: is there a published plan, and where?
The statement is the only one of the three that every company in UKLR 6, 16 and 22 must make.
| Source | Required? | |
|---|---|---|
| A transition plan | Company’s own choice | No |
| Information about any plan, its assumptions and dependencies | UK SRS S2 ¶14(a)(iv) | If there is a plan, comply or explain |
| Climate targets and progress | UK SRS S2 ¶¶33–36 | Comply or explain |
| Whether a plan is published, where, or why not | UKLR 6.6.6R(8)(e) | Yes, for UKLR 6, 16 and 22 |
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Two questions, and the statement’s shape
The rule has three branches, and a company takes exactly one.
The tree gives the shape of what to say, not the wording, because the reasons in the no-plan branch must be the company’s own.
The FCA does not set where a plan must be published.
A plan placed inside the strategic report is approved by the board with that report; one published elsewhere has no such step in the rule.
Where plans stand
Taskforce, consultation, guidance
The Transition Plan Taskforce Disclosure Framework remains the structure most UK plans borrow.
Its five elements are foundations, implementation strategy, engagement strategy, metrics and targets, and governance.
The IFRS Foundation’s material on disclosing transition information under IFRS S2 says it adds nothing to the requirements, and UK SRS S2 ¶14 uses the same words.
The government’s consultation on transition plan requirements closed in September 2025.
Any requirement to have a plan would come from the government’s consultation, not from this listing rule, which asks only whether one is published.
Climate targets themselves sit in UK SRS S2, whether or not there is a plan.
- Oct 2023TPT Disclosure Framework publishedFive elements, for voluntary use.TPT
- Oct 2024The Transition Plan Taskforce disbandsThe IFRS Foundation takes on its disclosure resources.IFRS Foundation
- Jun 2025IFRS Foundation transition-plan materialEducational; adds no requirement to IFRS S2.IFRS Foundation
- Jun–Sep 2025Government consults on transition plan requirementsNo outcome published when this page was checked.GOV.UK
- Sep 2026FCA final rules: the statement onlyWhether a plan is published, where, or why not.PS26/19
Frequently asked
Questions people ask
Does UK SRS require a transition plan?
No. UK SRS S2 paragraph 14(a)(iv) asks for information about any climate-related transition plan the entity has, including key assumptions and dependencies.
If there is no plan, there is nothing to describe under that item.
The FCA’s policy statement says UK SRS S2 does not require an entity to have a plan.
What is the UK SRS transition plan statement?
A statement required by UKLR 6.6.6R(8)(e) from listed companies in UKLR 6, 16 and 22, for periods beginning on or after 1 January 2027.
The company states whether it has published a climate-related transition plan, in its annual financial report or elsewhere; if it has, where it can be found; and if it has not, why not.
Do overseas issuers make the transition plan statement?
No. The statement does not apply to UKLR 14 (secondary listings) or UKLR 15 (depositary receipts), although those issuers are otherwise in scope of the UK SRS rules.
Are transition plans mandatory in the UK?
No UK law or rule requires a company to have or publish one.
The government consulted on transition plan requirements from 25 June to 17 September 2025; no outcome had been published when this page was last checked.
What framework should a UK transition plan follow?
None is required.
Many UK plans follow the five elements of the Transition Plan Taskforce Disclosure Framework, now hosted by the IFRS Foundation: foundations, implementation strategy, engagement strategy, metrics and targets, and governance.
The IFRS Foundation’s June 2025 material on transition plans under IFRS S2 adds no requirements and reads across to UK SRS S2.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- Financial Conduct AuthorityPS26/19 — full text, including the made instrument (UKLR 6.6.6R(7A), (7B), (8) and UKLR TP 16)
UKLR 6.6.6R(8)(e) as made, and the FCA’s statement that it is not requiring plans.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers’ sustainability disclosures with international standards (30 September 2026)
The final rules: comply or explain across UK SRS for UKLR 6, 14, 15, 16 and 22.
- Financial Conduct AuthorityFCA Handbook, UKLR 6.6 — annual financial report (as from 1 January 2027)
The rule the new disclosure limbs sit in.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures (25 February 2026)
¶14(a)(iv) on any transition plan; ¶¶33–36 on targets.
- Department for Business and TradeUK SRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (25 February 2026)
The general Standard, read at the paragraph.
- Department for Business and TradeClimate-related transition plan requirements — consultation (25 June to 17 September 2025)
The consultation on transition plans; no outcome published at the date of this page.
- IFRS FoundationDisclosing information about an entity’s climate-related transition, including information about transition plans, in accordance with IFRS S2 (June 2025)
Educational material that adds no requirement; it reads across to UK SRS S2 ¶14.
- IFRS Foundation (TPT archive)Transition Plan Taskforce Disclosure Framework (October 2023)
The five-element structure many UK plans still follow, voluntarily.
- IFRS FoundationIFRS S2 Climate-related Disclosures
The source text for UK SRS S2.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 — publication page
Where both Standards were published on 25 February 2026.
- Financial Conduct AuthorityCP26/5 — the consultation the final rules replace (30 January 2026)
Cited only for what was proposed, including a mandatory UK SRS S2 that the final rules dropped.
- legislation.gov.ukCompanies Act 2006, s.414CB — the non-financial and sustainability information statement
The separate Companies Act climate disclosure duty, which UK SRS does not replace.