CLLS FCA Consultation Working Group - Compiled Submissions - PELC and Company Law Committees - March 2026

The Committees support replacing TCFD-aligned rules with UK SRS S2, seeing this as better aligned with evolving international sustainability standards.

They support mandatory climate reporting in principle, but suggest phased or “comply or explain” reliefs, especially for Scope 3 emissions and smaller issuers.

They broadly support UK SRS S1 non-climate disclosures and transition plan disclosures on a flexible basis, but ask for clearer definitions, guidance and alignment with Government reforms.

On assurance, they favour transparency about voluntary third-party assurance for now, with any mandatory assurance introduced gradually, starting with limited assurance and narrower disclosure scope.