Climate-related financial disclosures have moved from the voluntary to the unavoidable. The UK government’s phased implementation of mandatory reporting requirements, built on the Task Force on Climate-related Financial Disclosures (TCFD) framework, now reaches well beyond the FTSE 100 firms that faced the earliest deadlines. Mid-sized companies, including those with more than 500 employees or a turnover above £500 million, are now squarely in scope, with obligations sitting across both FCA-regulated entities and certain Companies House filings. I’ve spoken with a number of finance directors and compliance leads over the past year, and the honest truth is that most mid-sized firms are starting from a standing position, with no sustainability team and little clarity on what exactly they need to produce.
What the current UK rules actually require
The UK’s mandatory TCFD-aligned reporting regime applies to different entities in different ways. Premium and standard listed companies on the London Stock Exchange must include TCFD-aligned disclosures in their annual reports, as directed by the FCA. Large private companies and LLPs that meet the size thresholds (broadly, those qualifying as large under the Companies Act 2006 with over 500 employees) must include climate-related financial disclosures in their strategic reports filed at Companies House. The FCA’s TCFD landing page lays out the split between listed entity obligations and wider expectations for asset managers and insurers, but if you are a sizeable private business, the Companies House route is where your obligations are likely to land.
The TCFD framework itself organises disclosure across four pillars: governance, strategy, risk management, and metrics and targets. You must explain how your board oversees climate-related risks, how those risks affect your business strategy, how you identify and manage them, and what metrics you use to track progress, including, where relevant, Scope 1 and Scope 2 greenhouse gas emissions. Scope 3 (supply chain and customer emissions) is encouraged but not uniformly mandated at this stage. None of this is light work, but it is structured enough that a methodical approach, even without a sustainability specialist, can get you to compliance.
Where mid-sized firms tend to get stuck
The governance section is usually the easiest place to start, because most firms already have some form of board discussion about risk. The harder part is translating those conversations into documented evidence of oversight. A board minute that explicitly references climate risk discussion is more useful here than a generic risk register entry. I’d recommend making climate a standing agenda item at board level and recording the substance of that discussion, not just that the topic arose.
Strategy disclosure is where things get genuinely difficult. You are expected to demonstrate that you have considered climate-related risks and opportunities across different time horizons, which implies some form of scenario analysis. The guidance allows for qualitative analysis where quantitative modelling is disproportionately burdensome, and for most mid-sized firms without a financial modelling team, that qualitative route is the realistic option. Be specific: describe the physical risks relevant to your sector (flooding, supply chain disruption, energy price volatility) and the transition risks (regulatory change, shifts in customer demand, carbon pricing). Vague assertions that “climate change presents risks” will not satisfy the requirement.
Metrics and targets consistently trip firms up because collecting Scope 1 and 2 emissions data for the first time is operationally demanding. You need energy consumption data from your sites, which means working with your facilities team or, if you operate from leased space, with your landlord. Some businesses reduce their energy costs at the same time by tightening up on efficiency, and firms like Westville are a reminder that physical improvements to building fabric are often part of the picture when companies start to get serious about understanding and reducing their energy footprint. For the disclosure itself, you need a defensible methodology, ideally the GHG Protocol, and consistent data across the reporting period.
A practical starting point for firms without a sustainability team
Treat the first disclosure as a baseline document rather than a polished sustainability report. The regulators understand that many organisations are disclosing for the first time, and a credible, honest first disclosure that acknowledges gaps and commits to improving data quality in subsequent years is far preferable to one that overstates capability. The TCFD framework’s own guidance explicitly allows for phased improvement.
Assign a named internal lead, almost certainly your Finance Director or Company Secretary, who coordinates the four pillars rather than trying to be a subject matter expert across all of them. They should draw on your existing operational, finance, and risk colleagues rather than treating this as a siloed sustainability exercise. If you already have ISO 14001 or an environmental management system in place, you have more raw material than you might think.
Consider whether your external auditors or accountants can support you here. Many UK accountancy practices now have climate disclosure advisory capability embedded in their offering; the growth of that specialism is part of a broader pattern I’ve written about before, where UK accountancy practices are expanding what they can deliver without proportionally increasing headcount. A good adviser will help you map your existing data to the TCFD structure rather than rebuilding from scratch.
One area where businesses often overlook their obligations is the intersection of these disclosures with wider Companies House filings. If you are already working through how to use Companies House data for competitive benchmarking, you will know that your strategic report is a public document, and your climate disclosures sit within it. That visibility cuts both ways: it is an opportunity to signal how your business is run, as well as a compliance obligation.
How the FCA’s Consumer Duty intersects for financial services firms
If your business operates in financial services, there is an additional layer to consider. The FCA’s expectations around climate risk are not confined to TCFD disclosures; they increasingly intersect with how firms communicate product risks to clients. Firms already working through their Consumer Duty obligations, which I’ve covered in detail in what the FCA’s Consumer Duty rules mean for fintech and financial software businesses, will find that climate risk disclosure is part of a broader shift in regulatory philosophy: the expectation that firms understand their risks, disclose them clearly, and demonstrate that they have thought carefully about the downstream effects on clients and the market.
What to do in the next 90 days
If your reporting deadline is approaching and you have not started, the priority order is straightforward. First, confirm whether you are in scope and under which route, FCA-regulated or Companies House. Second, collect your energy consumption data for Scope 1 and 2 and apply GHG Protocol conversion factors to produce an emissions figure. Third, draft your governance and risk management sections using existing board minutes and risk registers as source material. Fourth, produce a short scenario analysis, even a qualitative one, covering physical and transition risks relevant to your sector. Fifth, review the whole against the TCFD recommendations document before your legal or finance team signs it off.
None of this requires a sustainability team or a consultant charging day rates in the tens of thousands. It requires someone taking ownership, a structured methodology, and enough time to gather the underlying data. The firms that will struggle are those that treat this as someone else’s problem until the filing deadline is a fortnight away.
Frequently Asked Questions
Which UK companies are required to make climate-related financial disclosures?
Large UK-registered companies with more than 500 employees that meet the size thresholds under the Companies Act 2006 must include TCFD-aligned climate-related financial disclosures in their strategic reports filed at Companies House. FCA-regulated firms, including premium and standard listed companies, face additional obligations through FCA rules. Smaller companies are currently outside the mandatory scope, though voluntary disclosure is encouraged.
What is the TCFD framework and do UK businesses have to follow it?
The Task Force on Climate-related Financial Disclosures (TCFD) framework organises climate reporting across four pillars: governance, strategy, risk management, and metrics and targets. UK mandatory climate disclosure requirements are explicitly built on TCFD recommendations, so UK in-scope businesses must structure their disclosures using this framework. It is not optional for those who meet the size thresholds.
Do mid-sized UK businesses need to report Scope 3 emissions?
Scope 3 emissions, which cover indirect emissions in your supply chain and from customer use of your products, are encouraged under TCFD but not uniformly mandated for mid-sized UK companies at this stage. Scope 1 (direct emissions from operations) and Scope 2 (purchased energy) are the baseline expectation. Many firms are investing in Scope 3 data as a forward-looking step, but a credible first disclosure can focus on Scope 1 and 2 with a commitment to expand coverage.
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