Category: Climate insurance · Reviewed by Al Jabbar, Broker · Specialist Risks · Last reviewed 2026-06-10
The Task Force on Climate-related Financial Disclosures (TCFD) was an industry-led body established by the Financial Stability Board (FSB) in December 2015 to develop voluntary, consistent climate-related financial disclosures. Its Final Recommendations were published in June 2017 and became the global blueprint for climate disclosure, including the four-pillar structure (governance, strategy, risk management, metrics and targets) adopted by IFRS S2.
Category: Climate insurance Also known as: TCFD; Task Force on Climate-related Financial Disclosures; TCFD recommendations Established / Date: Established December 2015; Final Recommendations June 2017; disbanded October 2023 Related concepts: IFRS S2 climate disclosure, ISSB, Climate change insurance
The TCFD was created by the FSB at the request of the G20 Finance Ministers and Central Bank Governors to develop recommendations for voluntary climate-related financial disclosures consistent across sectors. Chaired by Michael Bloomberg, with vice-chair Mary Schapiro, the Task Force had 32 members spanning issuers, investors, insurers, banks, accounting firms and rating agencies.
The June 2017 Final Recommendations defined three categories of climate risk — physical, transition and liability — and structured disclosure around four pillars: governance (board oversight and management’s role), strategy (impact on business, scenario analysis), risk management (identification, assessment, integration), and metrics and targets (including greenhouse gas emissions).[1]
In October 2021, the TCFD issued updated guidance on metrics, targets and transition plans, alongside revised implementation annexes for non-financial sectors and for financial sectors (banks, insurance companies, asset owners and asset managers). The TCFD was formally disbanded in October 2023 once the IFRS Foundation took over monitoring responsibility through the ISSB.[2]
The TCFD itself was a voluntary framework. Its adoption became mandatory in the United Kingdom through several instruments. FCA Policy Statement PS20/17 (December 2020) introduced Listing Rule LR 9.8.6R(8), requiring premium-listed commercial companies to include a TCFD-aligned compliance statement on a “comply or explain” basis for accounting periods beginning on or after 1 January 2021.[3] PS21/23 (December 2021) extended this to standard-listed issuers.
The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 (SI 2022/31) inserted s.414CB(A1) into the Companies Act 2006, requiring TCFD-aligned disclosures from large companies and LLPs for financial years beginning on or after 6 April 2022.[4] The Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021 (SI 2021/839) applied a TCFD-aligned regime to the largest pension schemes from 1 October 2021.
Following TCFD disbandment, IFRS S2 carries the TCFD architecture forward as the global baseline.
UK insurers, Lloyd’s managing agents and asset managers are subject to TCFD-aligned reporting at group level (under FCA listing rules, Companies Act 2006 and PRA expectations under SS 3/19) and at scheme/fund level under FCA ESG Sourcebook rules (PS21/24, December 2021). The PRA references TCFD as a primary disclosure benchmark in its dialogue under SS 3/19.
Insurers also use TCFD-aligned disclosures from insureds as part of underwriting submissions, particularly for D&O, financial lines and large property programmes. The 2021 TCFD Annex for the insurance sector remains a useful reference for actuarial and underwriting practice in scenario analysis.
Lloyd’s published its first ESG Report in December 2020 explicitly aligned with TCFD pillars, and the Association of British Insurers, International Underwriting Association and Lloyd’s Market Association have all issued guidance on TCFD application.
UK businesses subject to either the FCA Listing Rule or the Companies Act 2006 s.414CB regime have built TCFD-aligned reporting capability since 2021-22. The architecture survives intact under UK SRS and IFRS S2, so the investment in governance, scenario analysis, transition planning and emissions metrics continues to deliver value.
For insurance buying, a credible TCFD-aligned disclosure remains the single best piece of evidence to present to D&O, financial lines and large property insurers. Brokers will draw on it directly when negotiating renewal terms.
A UK-listed retailer’s 2024 annual report contains its fourth annual TCFD-aligned disclosure, mapped to the four pillars and including scenario analysis under NGFS Net Zero 2050 and Current Policies pathways. The disclosure is used by its broker in placing D&O, EIL and property programmes, with insurers citing the maturity of governance and scenario analysis when offering renewal at flat pricing despite an industry hardening trend.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-10. Next review: 2026-12-10.
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