On 30 January 2026, the Financial Conduct Authority (FCA) published a consultation paper setting out proposals to evolve its rules in relation to listed companies’ sustainability disclosures (CP26/5).

Background

The FCA highlight in CP26/5 that there are already rules for listed companies’ sustainability disclosures that are aligned with the Task Force on Climate-related Financial Disclosures (TCFD), which was created in 2015 but disbanded in 2023, and that the International Sustainability Standards Board (ISSB) was established in 2021, to unify fragmented climate and wider sustainability reporting frameworks–including the TCFD. As a result, the FCA make clear that it considers that given the end of the TCFD and the transition to ISSB Standards its rules need to evolve.

Summary

The FCA explains in CP26/5 that around 40 jurisdictions are planning to adopt or use the ISSB Standards, including the UK, and the government is currently in the process of developing UK Sustainability Reporting Standards (UK SRS) to tailor the ISSB Standards for the UK. The FCA explains that it is consulting now, based on the draft UK SRS to ensure it has sufficient time to consult. However, the FCA further explains that once it has considered feedback and the UK SRS is finalised, it will finalise the proposed rules.

The current proposals include the following:

  • The FCA is proposing that companies in scope move to mandatory reporting against UK SRS S2, which covers climate disclosures and is an area where reporting is already high across companies.
  • The FCA is not proposing to require mandatory reporting of Scope 3 emissions data, which it proposes can continue to be reported on a ‘comply or explain’ basis.
  • The FCA sets out that it recognises that wider sustainability (non-climate) reporting (against UK SRS Scope 1) will be new to many of these listed companies and may present challenges and are therefore proposing that this non-climate reporting can be on a ‘comply or explain’ basis against UK SRS S1.
  • The FCA highlights that mandating that companies have transition plans is a matter for government. However, it also explains that in its view investors find this information useful and so it is proposing that companies in scope disclose whether and where they have published a transition plan, or the reason why not.
  • The FCA also propose requiring them to disclose whether they have obtained third-party assurance on sustainability disclosures.
  • The exception to the approach described above, is in relation to international companies that have their primary listing in another jurisdiction. To minimise duplication with requirements that international issuers face in the markets where they have their primary listing, the FCA is proposing a flexible approach. As the proposals focus on transparency of the sustainability-related reporting requirements and standards (including in relation to transition plans) applicable in an issuer’s primary listing location or place of incorporation, or any standards or requirements that such issuers voluntarily apply. Under these proposals, these issuers would also be required to disclose whether they have obtained third-party assurance on sustainability disclosures.

Next steps

The FCA has requested feedback on CP26/5 by 20 March 2026.