The new FCA compliance statement on TCFD disclosures

Observations from first reporters

We are delighted to present the results of our survey into how the first wave of December 2021 year-end reporters have approached the new TCFD reporting requirements.

The survey is based on the first 30 annual reports published by UK premium-listed companies with December 2021 year-ends. Encompassing a wide range of industries and including representatives from the FTSE 100, FTSE 250 and FTSE All-share indices, the survey illustrates how companies are adhering to the TCFD’s four recommendations & eleven recommended disclosures.

Key observations:

  • 90% of companies disclosed a clearly identified compliance statement in their annual report.
  • All companies indicated consistency with TCFD with respect to their Governance and Risk Management disclosures, in line with the FCA’s expectations in Listing Rule 9.8.6E.

Of those 21 companies presenting their TCFD disclosures wholly in the annual report:

  • 62% of companies stated that they have performed quantitative scenario analysis.
  • 13 companies stated that they had obtained independent external assurance over some or all metrics disclosed; all these companies gained assurance over at least Scope 1 and 2 emissions, with 11 also having obtained assurance over Scope 3 emissions.
  • All but one company disclosed a carbon reduction target, with the majority of these companies describing their target as ‘net zero’ or ‘carbon neutral’.
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