Mandatory TCFD Reporting in the U.K.: Key Requirements, Implications and Practical Impacts for Asset Managers

The U.K. Government has a legally binding obligation to reach “net-zero” greenhouse gas emissions by 2050. As part of its plan to achieve that goal, the U.K. Government has committed to mandatory climate-related disclosures, consistent with the recommendations of the Task Force on Climate-Related Financial Disclosures (TCFD), across most of the U.K. economy by 2025. For the asset management industry, the U.K. Financial Conduct Authority has taken the lead in proposing and implementing TCFD-aligned reporting rules (U.K. TCFD Rules). Similar TCFD-aligned reporting regimes have been proposed and/or implemented for U.K.-listed issuers, large private companies and certain categories of U.K. pension schemes. In a guest article, Travers Smith attorneys Simon Witney and Ibrahim Chaudhary provide an overview of the U.K. TCFD Rules relevant to asset managers; details on the entity- and product-level reporting required under the rules; and analysis of some emerging practical challenges for fund managers. For more on U.K. regulatory developments, see “Enhanced Warnings and Other Obligations From the FCA’s New U.K. Rules on Marketing High‑Risk Investments (Part One of Two)” (Dec. 1, 2022); “Key Differences Between U.S. and U.K. Marketing Rules and Tips for Dual Compliance (Part One of Two)” (Oct. 18, 2022); and “U.K. Treasury Outlines Potential Changes to Make Funds Regime More Attractive” (Jun. 28, 2022).

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