The consultation period on the TPT Disclosure Framework and Implementation Guidance is now closed.

At COP 27 the TPT published its Disclosure Framework and accompanying Implementation Guidance for consultation. It also launched a Sandbox for companies and financial institutions to test implementation.

  • The TPT Disclosure Framework (‘the Framework’) makes recommendations for companies and financial institutions to develop gold-standard transition plans.
  • The TPT Implementation Guidance (‘the Guidance’) sets out the steps to develop a transition plan, as well as when, where and how to disclose their plan.
  • The Sandbox will test the Framework and Guidance to help users and preparers create their own transition plans.

The consultation period on both the Disclosure Framework and Implementation Guidance closed on 28th February 2023. We thank everyone who has taken the time to engage with these documents and provide a response. We are currently analysing the feedback we have received and will take this into consideration in the next phase of our work.


High quality transition plans are crucial for the transition to net zero. Credible transition plans create transparency and accountability for companies and financial institutions to meet their net zero targets, and will enable investors to make better informed capital allocation decisions.

The Framework emphasises the need for concrete, short-term action by companies and financial firms across the economy. The TPT recommends that companies and financial firms consider the full range of levers at their disposal to contribute to, and prepare for, an economy-wide transition to net zero. This will help avoid potential unintended consequences of ‘paper decarbonisation’.

The Framework will inform future regulation in the UK. The TPT will use the consultation and Sandbox feedback to finalise the Disclosure Framework and Implementation Guidance. After this point the Financial Conduct Authority plans to draw on the TPT’s final outputs to strengthen their transition plan disclosure expectations of listed companies, asset managers and regulated asset owners.

The Disclosure Framework and Implementation Guidance can be accessed here.

Key concepts in the Framework and Guidance are set out in the Summary Recommendations.


Economic Secretary to the Treasury and Co-Chair of the TPT, Andrew Griffith MP, said:

“Transition Plans are fundamental to ensuring the financial system supports our transition to net zero – and I am grateful to the Taskforce for their ground-breaking work in this area.

The UK is already the leading global centre for sustainable finance, and today’s announcement is a significant step in delivering on our commitment made at COP26 last year – to become the world’s first net zero-aligned financial centre.”

Amanda Blanc, Group CEO of Aviva and Co-Chair of the TPT, said:

“In recent years, we have seen a wave of private companies announcing their ambitions to contribute to net zero. We now need financial firms and companies to come forward with high quality plans to show how they will meet their targets.

Transition plans are a key building block for delivering a net zero future. This is why the work of the TPT is so important. Building on the excellent work from GFANZ and the ISSB, the TPT Disclosure Framework will help ensure that everyone has a consistent understanding of what is needed. I am thrilled to co-chair the Taskforce and urge all those that are preparing 2023 transition plans to sign up for the TPT Online Sandbox and give feedback directly.”

David Schwimmer, CEO, LSEG

“The decision to make transition plan disclosures mandatory across the economy is a major step towards achieving the UK’s net zero target. The Disclosure Framework and Implementation Guidance from TPT provide clarity for companies looking to publish high quality, robust climate transition plans. The Framework draws on existing and emerging guidance from the TCFD and the ISSB and builds from GFANZ’s transition plan recommendations.

“Financial markets can only play a central role in decarbonising our economy with access to high quality, consistent and comparable data.  As other countries consider mandatory transition plans, this work could inform similar regulatory approaches around the world.”

Tanya Steele, WWF UK’s Chief Executive:

“One year after the Government’s historic promise at COP26 to make transition plans mandatory, we welcome the Taskforce’s robust guidance – as voluntary approaches are not enough.

“The nature and climate crises are two sides of the same coin – we won’t solve either unless we tackle both.  So, requiring companies to disclose the links between their emissions reduction plans and nature is an important first step towards world-leading, integrated guidance. The Taskforce’s Framework and Guidance can set a global example at COP27 – for both governments and businesses.”

Michelle Scrimgeour, CEO, Legal & General Investment Management 

“A critical element of delivering on our net zero commitment is understanding how the companies in which we invest are transitioning. LGIM is already assessing and engaging with over 1,000 companies through our Climate Impact Pledge. The TPT’s Disclosure Framework will enable consistent and comparable reporting of transition plans, which will be key for us to support our clients in transitioning their portfolios to net zero.”

Alison Rose, CEO NatWest

“Transition plans are a crucial tool for firms to set out and deliver on their net zero commitments, along with targeted public policy support. The TPT’s ‘whole of economy’ approach to transition planning recognises the contribution all companies, including those in the service sector with relatively low emissions, can play in enabling and accelerating the transition. The Framework crucially also gives space for organisations to set out the action needed from governments to implement a successful, economy-wide transition”

Mark Fawcett, Chief Investment Officer at Nest

“The Disclosure Framework and Implementation Guidance are key tools for companies to develop high-quality and comparable transition plans. It’s important this information is readily available – we want to manage the climate risk our members are exposed to and support our goal of being a net zero investor. We therefore urge companies to start developing transition plans and participate in TPT’s Sandbox.”

Michael Izza Chief Executive Officer, ICAEW

“The TPT’s Disclosure Framework and Implementation Guidance can play a key role in equipping UK Plc, including professional services, with the tools and knowledge needed to deliver on net zero commitments. The Implementation Guidance crucially covers how to report consistent, comparable and decision-useful information in transition plans, as well as how often and where to disclose transition plans.”

Sacha Sadan, ESG Director, FCA

“Our ESG strategy supports the role of finance in delivering a market-led transition to a more sustainable economy. We strongly welcome today’s publication of the Transition Plan Taskforce’s Disclosure Framework and Implementation Guidance. The FCA has been actively involved in the development and drafting of these initial outputs. We look forward to using the final outputs as we move to strengthen our transition plan disclosure expectations of listed companies and regulated firms.”

Mardi McBrien, Managing Director, International Sustainability Standards Board

“We welcome the work of the Transition Plan Taskforce (TPT) to drive robust and credible transition plans from finance and real economy actors. The TPT’s Framework and Guidance builds on the ISSB’s Climate Exposure Draft by providing further recommendations on transition plans for the UK context. The ISSB is pleased to sit on the Steering Group of the TPT and work towards global converge and standardisation on transition plans.”

Sarah Breeden, Executive Director for Financial Stability, Bank of England

“Climate change poses risks to the stability of the financial system and to individual firms. Actions taken by the private sector today will determine the size of future risks which is why it is crucial financial and non-financial firms develop and disclose robust transition plans with a focus on concrete short-term action. We welcome the publication of the TPT’s Disclosure Framework and Implementation Guidance which will be essential tools for firms developing their transition plans. The TPT’s guidance will be key in building out the transition infrastructure necessary for supporting the financial sector to allocate capital efficiently, enabling the real economy transition to net zero.”

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