Climate transition planning: Where are we now?

Climate transition planning: What’s new?

Since publication of our earlier article Climate transition planning: A step-by-step approach, the transition planning landscape has continued to evolve. There’ve been some important regulatory and policy developments in the UK and the EU, and it remains the case that businesses should be developing credible plans for the transition to a low-carbon economy.

UK sustainability reporting reforms have gathered pace

The UK government has published exposure drafts of UK Sustainability Reporting Standards (UK SRS S1 and UK SRS S2), based closely on ISSB standards IFRS S1 and IFRS S2, and consulted on their adoption. The proposed UK SRS regime is intended to form the foundation of the UK’s future sustainability disclosure framework. The standards are currently available for voluntary use, and the government has indicated that it will consider future requirements for economically significant companies. The FCA is now also developing a parallel framework for listed companies and other climate reporting measures.

These developments reinforce the importance of ensuring that climate-related governance, risk management, strategy and metrics are capable of supporting ISSB-aligned disclosures. A robust transition plan remains one of the most effective ways of demonstrating that readiness.

Significant changes to the EU sustainability timetable

In December 2025, the European Parliament adopted the final Omnibus I text, thereby simplifying Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive requirements. Key changes include raising the reporting threshold to over 1,000 employees and €450 million turnover, limiting due diligence to firms with over 5,000 employees/€1.5 billion turnover. Compliance is required by 2029.

While the aim is to ease immediate compliance pressures for some organisations, businesses should expect continued focus on climate-related governance, disclosure and transition planning, albeit on revised timelines and under a simplified regulatory framework.

The Transition Plan Taskforce (TPT) framework remains highly influential

The TPT Disclosure Framework and associated guidance remain among the most widely recognised resources for organisations developing climate transition plans, albeit responsibility for the TPT’s outputs has now been assumed by the ISSB. This change reflects the growing alignment between transition planning expectations and international sustainability reporting standards. As a result, organisations looking to prepare for future UK and international reporting requirements should continue to regard the TPT framework as a practical benchmark for good transition planning practice.

Climate transition planning: How we can help

We can work with businesses at every step of their journey to create, implement and deliver an effective sustainability strategy. Climate transition planning will be central to that. Our earlier article sets out a practical, step-by-step approach that remains helpful today. Specifically, we can help clients with:

• Measuring and assessing energy, carbon and climate risks
• Climate reporting/corporate disclosures
• Devising, drafting, implementing and maintaining a climate transition plan
• Carrying out sustainability/ESG due diligence, including sustainability-related audits, contract reviews and policy/procedure advice across the business and supply chain
• Updating and informing on sustainability-related developments
• Providing tailored training to staff at all levels
• Assisting with securing ‘green finance’ or investments based on sustainability criteria
• Delivering low carbon, sustainability and other green projects
• Providing comprehensive, cross-disciplinary advice and transactional assistance
• Risk management and dispute resolution strategies if/when sustainability queries, concerns or investigations arise.

Please contact Ben Sheppard to discuss the legal aspects of climate transition planning.