UKSIF response: Transition Plan Taskforce (TPT) consultation on Disclosure Framework and Implementation Guidance

In our response, we voice strong support for the TPT’s latest recommendations set out for private-sector companies to report against a transition plan, while noting some areas for further consideration. These areas include the following:

• Consideration from the TPT of ways to facilitate further consistency between the UK’s Disclosure Framework and international frameworks, such as GFANZ and the International Sustainability Standards Board (ISSB), while maintaining an objective and world-leading framework for the UK market. This could assist in the wider adoption of the UK’s framework across different jurisdictions in the coming years.
• Further guidance on practically embedding social and nature considerations into the upcoming Disclosure Framework, including through updates to the Implementation Guidance by the TPT ahead of this being finalised later this year. This work could seek to build better understanding among preparers and issuers on these specific areas and their envisaged treatment within transition plans.
• More broadly, we would strongly welcome the TPT considering further ways to promote understanding of transition plans among users and preparers and capacity building, particularly for smaller companies, which could promote greater adoption of these plans by issuers in the coming years. Additional ‘best-practice’ guides could be considered in the coming months, as well as dedicated ‘sandboxes’ on specific challenging areas to assist companies in producing their plans. For our members, some of them may have a relatively less advanced understanding of what ‘good’ looks like, reinforcing the importance of regular, ongoing guidance from the TPT and regulators as these plans are adopted in the economy. Given the high ambition shown in the Disclosure’s Framework, which we fully support, this will be a particularly important consideration for the TPT.
• Finally, we would like to see the TPT and wider stakeholders emphasise the case more clearly to policymakers that the value and robustness of companies’ transition plans continue to be heavily dependent on government’s own efforts to provide credible sectoral transition plans across the wider economy.

We look forward to continue supporting the work of the TPT over the coming months.

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