Scope
Are pension schemes in scope of UK SRS?
No.
CP26/5 addresses listed issuers across five UK Listing Rule categories (6, 14, 15, 16 and 22), with full UK SRS S2 reporting confined to categories 6, 16 and 22 and a lighter signposting statement for 14 and 15 — and the FCA is explicit that occupational pension schemes are not within its scope at allFCA CP26/5.
There is no proposal on the table to bring trustees into the FCA's listed-issuer regime, now or from 2027.
That does not mean pension schemes are unregulated on climate.
Large occupational schemes have been under their own statutory climate-governance regime since 2021, running on a different legal basis, a different timetable and a different regulator to everything else on this site SI 2021/839.
Why the gap exists
Two regimes that do not touch
UK SRS and the pension-scheme climate regime run on separate tracks, and the difference is worth setting out plainly, because it is easy to assume "sustainability reporting" means one thing across UK financial services.
It does not.
| UK SRS / FCA CP26/5 | Pension-scheme climate regime | |
|---|---|---|
| Legal basis | FCA Listing Rules (proposed) | SI 2021/839, made under the Pensions Act 1995 and 2021 |
| In force from | Proposed 1 Jan 2027 (not yet final) | 1 October 2021 (already in force) |
| Standard followed | IFRS S1 / S2 (ISSB) | TCFD-aligned, pre-ISSB framework |
| Who is caught | 515 listed issuers under UKLR 6, 16, 22 (plus 89 under UKLR 14/15, lighter-touch) | ~199 large DB/hybrid schemes, all master trusts and CDC schemes |
| Regulator | FCA | The Pensions Regulator (TPR) |
| Penalty for lateness | Not yet defined (proposal stage) | Mandatory minimum £2,500, no discretion |
The practical upshot: a large pension scheme sponsored by a listed bank or insurer may see its sponsor move onto UK SRS S2 from 2027, while the scheme itself continues reporting under the 2021 Regulations on an entirely separate clockSI 2021/839FCA CP26/5.
The obligation
What in-scope trustees must actually do
Schemes with £5bn or more in relevant assets came into scope from 1 October 2021DWP, June 2021; schemes with £1bn or more followed a year later, from 1 October 2022DWP, SI 2022/733.
Authorised master trusts and authorised collective money purchase (CDC) schemes are in scope regardless of asset sizeDWP, SI 2022/733.
Trustees of in-scope schemes must publish a climate change report within seven months of the end of the scheme year, free of charge on a publicly available websiteDWP statutory guidance, and must carry out scenario analysis in the first scheme year the requirements apply and at least every three scheme years afterwards DWP statutory guidance.
Four mandatory climate metrics
Absolute emissions
The total greenhouse-gas emissions attributable to the scheme’s investment portfolio.
Emissions intensity
Emissions expressed relative to a financial denominator, allowing comparison across scheme size.
Portfolio alignment
A metric describing alignment of the portfolio with limiting global warming to 1.5°C, mandatory from 1 October 2022.
One additional climate metric
Trustees select and disclose a further climate metric of their choosing, alongside the three fixed metrics.
The portfolio alignment metric is the fourth and most recently added requirement, sitting alongside the absolute emissions and emissions intensity metricsTPR guidanceDWP, SI 2022/733.
Where a scheme also runs financed-emissions-style portfolio calculations for other purposes, the underlying attribution mechanics are the same ones covered on the financed emissions page.
Enforcement
TPR's penalties are mandatory, and it has already used them
Where trustees fail to publish the report on time, TPR must issue a penalty — the £2,500 minimum is statutory, and TPR has no discretion to waive itTPR, Monetary penalties policy.
The maximum is £5,000 for an individual trustee and £50,000 for a corporate trustee, applied on a joint and several basis TPR, Monetary penalties policy.
This is not a theoretical risk.
TPR's first climate reporting fine was £5,000 against the trustees of the ExxonMobil Pension Plan, for a report due 31 July 2022 that was not accessible until 10 August 2022 because of a faulty URLTPR, regulatory intervention report.
TPR 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 climate change reports, both in the second half of 2024 TPR, penalty notices.
Coverage
How much of the pensions market this actually reaches
TPR's own figures put 199 defined-benefit and DB/DC hybrid schemes over the £1bn threshold, holding £781.1bn in aggregate assets and covering 59% of scheme membershipsTPR, Climate adaptation report 2025.
Add every authorised master trust and CDC scheme, and the regime reaches most of the assets that matter, even though the scheme count is smallDWP, SI 2022/733.
One corner remains genuinely unsettled: the Local Government Pension Scheme (LGPS).
MHCLG consulted on LGPS TCFD climate reporting between September and November 2022, and as at July 2026 no formal government response has been published — the consultation page still reads "We are analysing your feedback"MHCLG, checked 27 July 2026, though ministers confirmed by letter that requirements would not apply for the 2023/24 scheme year.
LGPS pooling companies are caught separately, as FCA-regulated AIFMs producing TCFD reports under FCA ESG 2 LGPS Central Limited — the same FCA asset-manager mechanics covered on the asset managers page.
What might change
Will UK SRS ever reach pension schemes?
Government has signalled it is thinking about this, but nothing has been decided.
In its June 2025 exposure-draft consultation, DBT committed that "DWP will review these regulations this year… the government will consider the role of UK SRS in reporting on climate-related matters by pension schemes"DBT, June 2025.
Separately, DWP has asked TPR to assess the practicalities of transition plans for pension schemes through an industry working group involving the largest occupational schemesDBT / DESNZ, June 2025.