The future of transition plans in the UK: From voluntary guidance to regulatory expectations

UK businesses are increasingly expected to publish credible transition plans. These plans show how a company intends to shift towards a low-carbon economy – not just in theory, but in practice. While transition plan disclosures have so far been encouraged rather than enforced, that is now changing. 

From guidance to regulatory signals 

The UK Government and the Financial Conduct Authority (FCA) have both indicated that transition plan disclosures could soon become more than just best practice. Since 2022, listed companies and large asset managers in the UK have been expected to disclose transition plans on a comply-or-explain basis under rules aligned with the Task Force on Climate-related Financial Disclosures. But the framework behind those plans is now evolving. 

At the centre of this shift is the work of the UK Transition Plan Taskforce (TPT). The TPT published its final disclosure framework in late 2023, offering clear guidance on how to prepare decision-useful transition plans. The framework is built around three key elements: ambition, action and accountability. 

The FCA is now preparing to consult on incorporating the TPT framework into its ESG disclosure rules. This consultation is expected in the second half of 2025. Meanwhile, the UK Government has launched a parallel consultation on whether to mandate transition plan disclosures for large UK businesses more broadly – not just listed firms and regulated financial institutions. 

What this means in practice 

These proposals would mark a significant change for ESG and sustainability reporting if adopted. Businesses would no longer be judged only on their current emissions or climate risks – they would also be expected to show how they plan to adapt their business model over time. 

A credible transition plan under the TPT framework includes: 

• a clear long-term ambition aligned with climate goals such as net zero 
• interim targets and strategic levers to achieve that ambition 
• detailed actions across operations, supply chains, capital allocation and engagement 
• governance and accountability mechanisms to track progress. 

For businesses, this means bringing together multiple functions – sustainability, finance, strategy, risk and legal – to build an integrated and credible roadmap. 

Why this matters for UK businesses 

The shift from voluntary to potentially mandatory transition planning raises several challenges. 

Many companies have never created a formal transition plan. Others have published general statements of intent but lack detailed targets or timelines. The TPT framework sets a much higher bar – and one that investors are likely to start expecting even before regulations catch up. 

Producing a credible plan requires reliable data, cross-functional alignment and clear governance. Businesses must strengthen internal capabilities and review whether their existing systems can support more detailed disclosures. 

Transition plans are increasingly being used by financial institutions to assess credit and investment risk. Companies that do not produce convincing plans could face questions about their long-term viability or capacity to access finance on competitive terms. 

A business opportunity, not just a compliance task 

While the emerging rules may feel like another reporting requirement, they also offer a strategic opportunity. A well-developed transition plan can clarify how the business will remain competitive in a decarbonising economy. It can help attract investment, support customer relationships and strengthen engagement with employees and suppliers. 

Early adopters are already seeing benefits. In the financial sector, firms use the TPT framework to guide their lending decisions and support client engagement. In manufacturing and energy, companies use transition plans to communicate long-term strategy and attract green capital. 

Conclusion 

The UK is moving towards a future where transition plan disclosures are recommended and expected. For businesses, the time to act is now. Using the TPT framework as a guide, companies can build credible, actionable plans that meet both investor demands and potential regulatory requirements. 

If you’d like to learn more about how Speeki supports UK businesses with ESG management and reporting, please visit this page.