UK Taskforce's best-practice transition plan framework

This is a best-practice framework for firms to disclose their climate transition plans, and how they intend to transition their operations and value chains to net zero. It represents a potentially vital contribution to the UK’s target of Net Zero by 2050 and may also influence transition planning and disclosure well beyond the UK’s shores.

Here we provide an overview of the published framework and the implications for financial service providers.

What is the TPTF?

The Transition Plan Taskforce Framework (“TPTF”) builds on recommendations from the Taskforce for Climate-related Financial Disclosures (“TCFD”), the Glasgow Financial Alliance for Net Zero (“GFANZ”) and the International Sustainability Standards Board (“ISSB”). Having been specifically designed to complement the ISSB’s International Financial Reporting Standards (“IFRS”) S2, the TPTF is intended to assist entities in making their transition planning disclosures. Furthermore, in March of this year, the UK Government reaffirmed its intention of implementing compulsory reporting aligned with the ISSB standards (HM Government 2023).

The Financial Conduct Authority (“FCA”) has endorsed the TPT framework, describing it as "a set of good practice recommendations to help companies across the economy make high quality, consistent, and comparable transition plan disclosures" (Financial Conduct Authority 2023).

Who is affected by this?

Listed companies, asset managers, and asset owners will be affected by the TPTF. Detailed sector-specific guidance is expected by the end of this month for asset management, asset owners, and banking sectors, as well as food and beverage, electric utilities and power generators, metals and mining, and oil and gas.

Financial service providers in the scope of the FCA’s upcoming Sustainable Disclosure Requirements will also be impacted by the TPTF. Following implementation, the metrics used within assets’ transition plans could be incorporated into the key performance indicators (“KPIs”) leveraged by firms with “Sustainable Improvers” funds.

The TPTF’s potential reach extends beyond the UK. The Corporate Sustainability Reporting Directive and the expected Corporate Sustainability Due Diligence Directive both require disclosures regarding transition plans for in-scope companies. While developed with the UK economy in mind, the TPTF is also deliberately designed to be transferable and is the first such national- level transition framework to emerge globally. It might be anticipated, therefore, that the framework may be leveraged to inform these EU requirements. Even if not formally adopted by the EU, the framework may become a de facto “standard” for companies in the absence of any competing guidance.

Guiding principles of the TPTF

The TPTF applies three guiding principles: Ambition, Action, and Accountability. The Framework is then assembled across five elements, as shown below, which are consistent with the transition planning aspects proposed by GFANZ.

Figure 1. TPT Disclosure Framework.

1. Ambition relates to the necessity for entities to consider the broader impact of their climate transition goals on other sustainability objectives so they must set a “Strategic Ambition”. This must be done via a “strategic and rounded” approach which includes considering opportunities, minimising risks, and strengthening long-term value.
2. Action describes how the ambitions of the entity are translated into clear steps. A roadmap of short, medium, and long-term goals is expected. Best-practice transition plans should focus on carbon reduction, while consistently seeking to reduce risks wherever possible.

• Accountability refers to the governance behind an entity and its transition plan. Information should include roles, responsibilities, and reporting processes in place.

How can you prepare?

Although the ISSB standards and TPTF will not immediately replace the TCFD framework for transition disclosure, companies and entities affected should consider reporting in line with the TPTF on a voluntary basis.

Voluntary reporting will enable early sight of data, governance, and implementation gaps as well as opportunities to improve, giving a head start to entities taking this step.

How can we help?

We offer a range of services that will help to streamline TPTF alignment and/or voluntary disclosure.

Our Carbon and Climate services include carbon assessment across Scope 1, 2 and 3 as well as advisory support for carbon reduction roadmaps and emission reduction target-setting which are referenced in the TPTF. We can also provide a fully TCFD-aligned climate risk assessment report for your firm. Our wider platform offerings will aid entities in KPI monitoring, collection, and interpretation.

As part of our Carbon and Climate support, we also offer a range of regulatory services. Entities are required to report on any targets required by law and must stay aware of policy and regulatory changes in their jurisdictions. We support our clients with regulatory roadmaps, alignment, and strategy support.

Conclusion

The TPTF’s release is a significant step forward in shaping climate transition planning disclosures and its reach may well extend beyond the UK’s shores. It is aligned with global standards like TCFD, GFANZ, and ISSB and the FCA's endorsement highlights its importance for a wide range of sectors.

Preparation should involve voluntary reporting against the TPTF, providing a head start for entities to address gaps ahead of implementation.

Additional resources

For more information about the current status, next steps, and detailed requirements, please read the TPT Disclosure Framework in full.

To find out more, please contact the team.

References:

HM Government (2023) Mobilising Green Investment: 2023 Green Finance Strategy. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1149690/mobilising-green-investment-2023-green-finance-strategy.pdf

Financial Conduct Authority (2023) FCA welcomes the launch of the Transition Plan Taskforce Disclosure Framework. Available at:https://www.fca.org.uk/news/news-stories/fca-welcomes-launch-transition-plan-taskforce-disclosure-framework