New TPT framework hailed as ‘a vital step forward’

A new framework designed to channel finance towards businesses committed to cutting greenhouse gas emissions in their operations has been embraced by the sustainable investment community as the Transition Plan Taskforce’s framework is hailed as “an example of what gold standard climate standards should look like.”

The 45-page TPT’s disclosure document, which was launched yesterday, details a framework that encourages businesses to develop plans on how they will transition to ‘a low GHG-emissions, climate-resilient economy’, and it makes a series of disclosures in relation to those plans.

The framework is initially voluntary for businesses to adopt, the new disclosure standards could come into force for the 2025 accounting period with reporting to begin from 2026 on.

Euan McVicar of City law firm Pinsent Masons said the final TPT framework is the most considered and well-developed in respect of transition plans, globally. He calls on businesses not to delay in considering how they engage with it.

“The launch of the final TPT framework is significant; the direction of travel remains for the requirements to become increasingly mandatory,” McVicar told Net Zero Investor.

“While the proposals have taken account of consultation responses calling for greater guidance on a number of aspects, the proposals will remain challenging for many, especially those who have only recently engaged or are yet to engage with TCFD disclosures,” he added.

Transition Plan Taskforce

The UK’s Transition Plan Taskforce, an initiative launched by the UK government during COP26, is aimed enhancing disclosure standards on meeting climate targets, managing climate related risks and contributing to economy-wide climate transition.

The TPT framework is comprised of representatives from across business, academia, civil society, government and regulators.

The new framework distinguishes between ambitions, actions and accountability with investors being not just required to outline their ambitions on net zero and the actions they plan to take in implementing them, but also linking compliance to board oversight and reporting and even financial remuneration.

The new disclosure standards could come into force for the 2025 accounting period with reporting to begin from 2026 on.

Net Zero Investor's Annual Conference | 11th December 2023 | London

Thumbs up

Responding to the launch, Mark Kenber, executive Director of the London-based Voluntary Carbon Markets Integrity Initiative (VCMI), told Net Zero Investor he gives the framework a resounding thumbs up.

“Credible transition plans require full transparency on the basis of comprehensive disclosure rules that include all corporate climate action, including the use of carbon credits,” he noted.

“The TPT provides this,” Kenber said firmly.

Nicolette Bartlett, chief impact officer at global disclosure platform CDP, said “credible transition plans are an essential tool to ensure the global economy transitions in line with a 1.5°C pathway."

She shared with Net Zero Investor that “the launch of the disclosure framework is a vital step towards ensuring the private sector has the tools it needs to develop credible transition plans.”

In 2022, only 28% of UK companies disclosing through CDP said they had a transition plan. 

“This guidance is essential in increasing that number,” Bartlett argued.

Meanwhile, Rob Doepel, EY's UK managing partner for sustainability, was equally positive, calling the publication of the framework “a vital step forward in the UK's Net Zero journey.”

Doepel told Net Zero Investor this morning that “it provides businesses with a roadmap to developing their own credible, actionable transition plans.”

In fact, he went on to say: "The framework is an example of what gold climate standards should look like: co-developed between public and private sectors, aligned with international bodies and a consistent focus on ambitious, meaningful action that has to be backed up with evidenced progress.”

‘First step’

UK-listed asset managers and owners with more than £5bn in assets are in most cases already required to disclose TCFD reports, but the TPT framework could go beyond that, as Sam Gill, co-founder and COO at Carbon data provider Sylvera explained.

“The proposed disclosures include not just emissions reduction measures but also carbon credit activity – a boon for further transparency and clarity to how companies engage with the carbon markets,” he noted.

“Put into regulation, such disclosures would be a big step forward for kicking corporate climate action into gear.”

However, Gill did stress that “disclosures are only the first step. To truly drive net zero forward, we need governments to increase focus on decarbonisation delivery sector by sector.”

The new TPT reporting framework is set up to complement and build on the International Sustainability Standards Board (ISSB) and draw on the Glasgow Financial Alliance for Net Zero (GFANZ) framework for transition planning.

McVicar urged investors and corporates to start transition planning, even if the TPT gold standard cannot be met right away.

“Reporting of TPT-aligned transition plans looks set to be increasingly mandatory” as he pointed out that the Financial Conduct Authority (FCA) plans to mandate TPT-aligned transition plans for listed companies in the first quarter of 2024.

“There had been some concern on this given row-backs on other green policies in the UK,” McVicar noted.

“The ability of transition plans to rapidly help organisations respond to climate-related risks and opportunities, decarbonise, and contribute to economy-wide transitions, needs mainstream disclosure. Many will feel that the pace and scope of mandatory requirements are insufficient to be transformational.”

McVicar stressed that, under the framework, businesses need to outline the strategic ambition of their transition plans, set out the actions they are taking to achieve that ambition, how they are engaging those in their value chain with their ambition, the metrics and targets they have set to help them monitor progress towards achieving their ambition, and how they are embedding the transition plan within their governance structures and organisational arrangements.

As McVicar pointed out, the FCA has embraced the new framework. 

Sacha Sadan, director environmental, social and governance at the financial services watchdog, called the framework "an important step."

She explained: "Companies will need to think strategically about how they respond and contribute to the transition to a low emissions, climate-resilient future. The framework an important step in this transformation."

Sadan stressed the framework "will help companies communicate high-quality, consistent and comprehensive information on their transition plans to investors, giving them the confidence to finance the transition."

The announcement has also been welcomed by GFANZ chair Mary Schapiro.

“This framework, which builds on the best practice framework developed by GFANZ in 2022, will play a critical role in ensuring that UK companies and financial institutions develop and disclose credible and comprehensive transition plans needed to drive the net zero transition” she said.

'Global applicability by design'

While a UK initiative, the TPT’s disclosure framework has been developed with broader international standards in mind – perhaps most notably new standards published by the International Sustainability Standards Board (ISSB) in the summer.

In their foreword to the new framework, co-chairs of the TPT Steering Group, Aviva Group chief executive Amanda Blanc and Treasury minister Baroness Penn, said the TPT framework “has global applicability by design”, citing its alignment with both the ISSB standards and the transition plan guidance developed by the Glasgow Finance Alliance for Net Zero (GFANZ).

Sue Lloyd, vice-chair of the ISSB, said the TPT’s framework “provides a practical and useful complement” to the ISSB standards.

McVicar said that the significance of the TPT’s work is reflected by the large volume of responses it received to its consultation on its draft proposals from industry and other stakeholders.

In addition to the release of the European Sustainability Reporting Standards (ESRS) comparison and technical mapping against the TCFD recommendations and IFRS S2, the TPT is set to consult on sector-specific guidance in November for publication in early 2024.

Also read
Taking stock of physical risks: investors could be in for a ‘rude awakening’