UK SRS · Pension schemes
UK SRS for pension schemes: outside one regime, bound by another
UK SRS for pension schemes has a short answer: trustees of occupational schemes are not reached by UK SRS or by the FCA’s new listing rules.
Large schemes have instead been under a mandatory, TCFD-aligned climate regime of their own since 1 October 2021, made under pensions law and enforced by the Pensions Regulator.
Its penalty for failing to publish is mandatory, with a £2,500 floor, and it has been used.
Scope
Are pension schemes in scope of UK SRS? No
UK SRS S1 and S2 are available for voluntary use by any entity, and no instrument requires a pension scheme to use them.
The FCA’s final rules, published on 30 September 2026 in PS26/19, apply UK SRS to listed companies on a comply-or-explain basis.
Trustees of an occupational pension scheme are not listed issuers, so the rules the FCA consulted on in CP26/5 do not reach them.
That does not leave schemes unregulated on climate.
Large occupational schemes have reported under the Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021 since 1 October 2021, on a different legal basis, timetable and regulator from everything else on this site.
A scheme sponsored by a listed bank or insurer may therefore see its sponsor report against UK SRS from 2027 while the scheme reports under the 2021 Regulations on its own clock.
The listed-company routes that do apply across financial services are on the UK SRS for financial services hub.
| UK SRS via FCA PS26/19 | Pension-scheme climate regime | |
|---|---|---|
| Legal basis | FCA listing rules | SI 2021/839, made under pensions law |
| Status | Final; periods from 1 Jan 2027 | In force since 1 Oct 2021 |
| Framework | UK SRS S1 and S2 (ISSB) | TCFD-aligned |
| Who | Listed companies (UKLR 6, 14, 15, 16, 22) | Trustees of large schemes, master trusts, CDC schemes |
| Basis | Comply or explain | Mandatory |
| Regulator | FCA | The Pensions Regulator |
The 2021 Regulations
What in-scope trustees must actually do
The thresholds were staged in SI 2021/839 as made: £5bn from 1 October 2021 and £1bn from 1 October 2022.
Authorised master trusts and authorised collective money purchase (CDC) schemes are in scope while authorised, whatever their size.
In-scope trustees must establish governance of climate-related risks and opportunities, carry out scenario analysis, identify and manage climate risks, select metrics and set a target.
The DWP’s statutory guidance puts scenario analysis in the first scheme year the requirements apply and at least every three scheme years after that.
The Regulations require at least two scenarios, one of them within the range of 1.5°C to 2°C of warming above pre-industrial levels.
The report must be published within seven months of the end of the scheme year, on a publicly available website, free of charge, and the Pensions Regulator is told through the scheme return.
The Pensions Regulator’s detailed guidance sets out how it expects trustees to meet each duty, and the policy background is in the DWP’s consultation response on the draft Regulations.
- 1 Oct 2021£5bn and over
Relevant assets of £5bn or more at the first scheme year end on or after 1 March 2020.
- 1 Oct 2022£1bn and over
Relevant assets of £1bn or more at the first scheme year end on or after 1 March 2021.
- Any sizeMaster trusts and CDC schemes
While authorised, from 1 October 2021 or authorisation.
- < £500mFalling out
Ongoing duties cease if relevant assets fall below £500m at a later year end; one final report is still due.
Source: SI 2021/839 regs 3–5
Metrics
Four mandatory metrics, one added in 2022
The DWP guidance asks trustees to select and report a minimum of one metric in each of four categories (¶118).
Absolute emissions
The total greenhouse gas emissions attributable to the scheme’s assets.
Emissions intensity
Emissions relative to a financial denominator, so schemes of different sizes can be compared.
Portfolio alignment
How far the assets align with limiting warming to 1.5°C — added by SI 2022/733 from 1 October 2022.
One additional climate metric
A further climate change metric of the trustees’ choosing.
SI 2022/733 did one thing: it inserted the portfolio alignment metric.
It did not lower the asset threshold, which was already £1bn in the 2021 Regulations.
The attribution arithmetic behind absolute emissions and intensity is the same as for any portfolio, and is covered on the financed emissions reporting page.
Enforcement
The penalty is mandatory, and it has been used
Regulation 9(2) says the Pensions Regulator must issue a penalty notice where trustees fail to publish the report on a publicly available website, free of charge.
That penalty must be at least £2,500, and no penalty under the Regulations may exceed £5,000 for an individual or £50,000 for a body corporate or other person.
A notice to trustees goes to all of them, jointly and severally liable.
The Pensions Regulator’s monetary penalties policy says it has no discretion not to issue the mandatory penalty, and that the penalty relates to publication, not content.
Every other breach of the Regulations attracts a discretionary penalty under regulation 9(1), with no floor.
The first climate reporting fine went to the trustees of the ExxonMobil Pension Plan: £5,000, issued in May 2023 (TPR regulatory intervention report).
Their report was due by 31 July 2022 and had been produced, but a faulty URL meant it was not on a publicly available website until 10 August.
TPR’s penalty notices for 1 July to 31 December 2024 record fines for late climate change reports to the trustees of the University of Oxford Staff Pension Scheme (£5,000) and the J.P. Morgan UK Pension Plan (£4,000).
A report that exists but sits behind a broken link has not been published.
Check the live URL on the deadline day, not just the upload.
Reach
How much of the pensions market this reaches
The Pensions Regulator’s Climate adaptation report 2025, published on 10 April 2025, says around 300 defined benefit, defined contribution and hybrid schemes have had to prepare TCFD reports.
The same report counts 220 defined benefit and hybrid schemes with more than £1 billion of assets.
Contract-based pensions sit elsewhere: FCA-regulated pension providers are asset owners under FCA ESG 1A.1.1R and follow the FCA’s TCFD rules, whose product-level limb was simplified on 25 September 2026 (Handbook Notice 144).
One corner remains unsettled: the Local Government Pension Scheme in England and Wales.
The government consulted on LGPS climate reporting from 1 September to 24 November 2022, and the consultation page still reads “We are analysing your feedback”.
LGPS pooling companies are reached separately, as FCA-regulated fund managers; LGPS Central, for example, publishes TCFD disclosures as an FCA-regulated AIFM.
Those are the same FCA rules covered on the UK SRS for asset managers page, and the manager-side product rules on the SDR investment labels page.
What next
Will UK SRS ever reach pension schemes? Not decided
The government has said it will think about it, and nothing more.
In its June 2025 UK SRS exposure-draft consultation, it said the DWP would review the 2021 Regulations that year, building on evidence from the Pensions Regulator.
It added that the government would consider the role of UK SRS in pension schemes’ climate reporting as part of that review.
We have not found a published outcome, call for evidence or proposal as at 30 September 2026.
Until one appears, the 2021 Regulations are the rule, and a statement that the review has “reported” should be checked against GOV.UK before it is repeated.
How the ISSB standards compare with the TCFD framework the schemes use is on our IFRS S1 and S2 page.
This page is an independent reference, not pensions or legal advice; to talk a scheme’s position through, you can book a free 15-minute call.
Frequently asked
Questions people ask
Do UK SRS or the FCA’s new rules apply to pension schemes?
No. UK SRS S1 and S2 are available for voluntary use, and the FCA’s final rules in PS26/19 (30 September 2026) apply to listed companies. Trustees of occupational pension schemes are not listed issuers, so neither reaches them.
What climate reporting rules apply to pension schemes?
The Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021 (SI 2021/839), in force from 1 October 2021. Schemes with £5bn or more in relevant assets came into scope from 1 October 2021, schemes with £1bn or more from 1 October 2022, and authorised master trusts and authorised collective money purchase schemes are in scope while authorised, whatever their size.
When must trustees publish their climate change report?
Within seven months of the end of the scheme year, on a publicly available website that can be accessed free of charge. The Pensions Regulator is notified through the scheme return.
What metrics must trustees report?
Four: an absolute emissions metric, an emissions intensity metric, a portfolio alignment metric and one additional climate change metric. The portfolio alignment metric was added by SI 2022/733 and has applied since 1 October 2022.
How often must trustees carry out scenario analysis?
In the first scheme year the requirements apply, and then at least every three scheme years, according to the DWP’s statutory guidance. Trustees review the analysis in the years between and must redo it if the review says it is needed.
What happens if trustees miss the publication deadline?
Regulation 9(2) of SI 2021/839 says the Pensions Regulator must issue a penalty notice where trustees fail to publish the report on a publicly available website. That penalty must be at least £2,500, and no penalty under the Regulations may exceed £5,000 for an individual or £50,000 for any other person. The Pensions Regulator says it has no discretion not to issue the mandatory penalty.
Has the Pensions Regulator fined anyone for climate reporting?
Yes. Its first fine was £5,000 to the trustees of the ExxonMobil Pension Plan, whose report was due by 31 July 2022 but, because of a faulty URL, was not on a publicly available website until 10 August 2022. It has since fined the trustees of the University of Oxford Staff Pension Scheme (£5,000) and the J.P. Morgan UK Pension Plan (£4,000) for late reports, in its penalty notices for 1 July to 31 December 2024.
Could pension schemes move onto UK SRS in future?
The government has said it will consider it. In its June 2025 UK SRS exposure-draft consultation, it said the DWP would review the 2021 Regulations that year, building on evidence from the Pensions Regulator, and that the government would consider the role of UK SRS in pension schemes’ climate reporting. We have not found a published outcome of that review as at 30 September 2026.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.
- legislation.gov.ukSI 2021/839 — Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021
Regs 3–5 scope and thresholds; reg 6 reporting and publication; the Schedule on governance, scenarios and metrics.
- legislation.gov.ukSI 2021/839, regulation 9 — penalty notices
9(2) mandatory penalty for failure to publish; 9(4) at least £2,500, capped at £5,000 / £50,000.
- legislation.gov.ukSI 2022/733 — Explanatory Memorandum
The portfolio alignment metric; the instrument changed no asset threshold.
- Department for Work and PensionsStatutory guidance: governance and reporting of climate change risk, ¶¶84, 118
Scenario analysis in the first scheme year and at least every three scheme years; the four metrics.
- Department for Work and PensionsTaking action on climate risk: improving governance and reporting by occupational pension schemes
The DWP response and consultation on the draft Regulations.
- The Pensions RegulatorClimate-related governance and reporting — detailed guidance
TPR’s guidance for in-scope trustees.
- The Pensions RegulatorMonetary penalties policy, Appendix 3
“We have no discretion not to issue a penalty notice in these circumstances.”
- The Pensions RegulatorExxonMobil Pension Plan — regulatory intervention report
TPR’s first climate reporting fine: £5,000, issued May 2023, paid July 2023.
- The Pensions RegulatorPenalty notices
Climate reporting fines, 1 July to 31 December 2024.
- The Pensions RegulatorClimate adaptation report 2025 (10 April 2025)
220 DB and hybrid schemes over £1bn; around 300 schemes have prepared TCFD reports.
- Financial Conduct AuthorityPS26/19 — Aligning listed issuers’ sustainability disclosures with international standards (30 September 2026)
Applies to listed companies; trust-based schemes are not listed issuers.
- Financial Conduct AuthorityCP26/5 — consultation landing page
The listed-issuer consultation PS26/19 answers.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
UK SRS is available for voluntary use by any entity.
- Department for Business and TradeExposure draft of UK SRS S1 and S2 (June 2025)
“The Department for Work and Pensions (DWP) will review these regulations this year…”
- Department for Levelling Up, Housing and CommunitiesLGPS (England and Wales): governance and reporting of climate change risks — consultation
Ran 1 September to 24 November 2022; status “We are analysing your feedback”.
- Financial Conduct AuthorityFCA Handbook ESG 1A.1 — asset owners in scope of ESG 2
FCA-regulated pension providers of contract-based schemes.
- Financial Conduct AuthorityHandbook Notice 144 (September 2026)
FCA 2026/59, in force 25 September 2026, for FCA-regulated pension providers among others.
Continue reading
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