Policy Briefing — UK FCA TCFD Rule for Premium Listed Issuers
The UK Financial Conduct Authority finalised PS20/17 on December 21, 2020, requiring premium listed companies to include TCFD-aligned climate governance disclosures in their annual reports for periods beginning in 2021.
Executive briefing: On 21 December 2020 the UK Financial Conduct Authority (FCA) published Policy Statement PS20/17, confirming new Listing Rule 9.8.6R(8) that forces premium listed commercial companies to disclose how their boards oversee climate-related risks consistent with the Task Force on Climate-related Financial Disclosures (TCFD). Issuers must either attest to full TCFD alignment in their annual report or explain deviations, while the FCA simultaneously updated its Technical Note to spell out governance and scenario-analysis expectations.
What changed
- Mandatory comply-or-explain reporting. Annual financial reports for accounting periods beginning on or after 1 January 2021 must include a TCFD statement covering governance, strategy, risk management, and metrics and targets, replacing previous voluntary guidance.
- Board accountability for climate oversight. The FCA clarified that boards must evidence how they monitor climate risks and opportunities, including assigning oversight to audit or risk committees and describing scenario analysis.
- Market guidance for assurance and controls. Primary Market Bulletin 32 and Technical Note 801.2 point issuers toward internal controls, assurance roadmaps, and data governance needed to support the TCFD statement.
Implications for operators
- Public sector and sovereign issuers. UK government-owned companies and sovereign-linked issuers must embed TCFD governance in departmental assurance frameworks and shareholder letters.
- Financial institutions. Banks and insurers with London listings need to align Pillar 3, Solvency II, and Own Risk and Solvency Assessment (ORSA) governance disclosures with the new listing obligation.
- Technology and data-heavy firms. Tech issuers must operationalise climate data governance, linking sustainability tooling with board reporting packs for premium listing compliance.
Action checklist
- Update board and committee charters to map climate risk oversight responsibilities and escalation pathways.
- Integrate TCFD-aligned scenario analysis and controls testing into the annual report production calendar.
- Align investor-relations Q&A scripts and sustainability microsites with the FCA’s TCFD statement requirements.
Sources
Zeph Tech guides governance and finance teams through TCFD controls, board reporting, and assurance scheduling for FCA premium listings.
Follow-up: FCA extended TCFD-aligned reporting to standard listed issuers in 2022 and asset managers in 2023, and its 2024 consultations prepare for integrating ISSB climate disclosures into the UK Sustainability Disclosure Requirements.