DEEP DIVE
TPT, ISSB, and the Transition Plan Regulatory Landscape
Understanding who sets the rules and how the frameworks connect.
In 30 Seconds
The transition plan regulatory landscape is confusing because multiple organizations create overlapping guidance. Here's what you need to know: ISSB sets the global standard for what to disclose (IFRS S2), and TPT provides the practical framework for how to structure credible plans. IFRS adopted TPT's materials in 2024, making them the de facto implementation guide.
Bottom line: Use TPT to build your plan. It meets ISSB requirements and travels across jurisdictions.
The Timeline
TPT Established
UK government creates Transition Plan Taskforce to develop disclosure guidance. Initial mandate: create practical framework for corporate climate transition plans.
TPT Development
TPT engages 600+ organizations globally (financial institutions, corporates, regulators, civil society). Develops comprehensive 5-element framework, sector guidance, and implementation materials.
TPT Framework Published
TPT publishes complete Disclosure Framework with detailed recommendations. Framework organizes transition plans into 5 elements: Foundations, Implementation Strategy, Engagement Strategy, Metrics & Targets, Governance.
IFRS Adoption
IFRS Foundation adopts 13 of TPT's disclosure-specific documents. This gives TPT global reach and integrates it with ISSB standards (IFRS S2). Materials now owned by IFRS Foundation.
TPT Concludes
TPT officially completes its mandate on October 31, 2024. IFRS Foundation now maintains and promotes TPT materials as implementation guidance for IFRS S2 climate disclosures.
How They Connect
ISSB / IFRS S2
What it is: Global sustainability disclosure standard created by International Sustainability Standards Board (ISSB).
What it requires: Companies must disclose climate-related risks, opportunities, governance, strategy, metrics, and transition plans.
What it doesn't tell you: How to structure a credible transition plan. The standard defines what to disclose but not how to build it.
TPT Framework
What it is: Practical implementation framework developed by UK Transition Plan Taskforce, now owned by IFRS Foundation.
What it provides: Detailed "how-to" guidance for structuring, developing, and disclosing credible transition plans. 5-element framework with specific sub-elements and disclosure recommendations.
Why it matters: TPT is the implementation manual for the transition plan requirements in IFRS S2.
The Relationship
climate transition plans"
and disclose credibly"
A Simple Analogy
ISSB / IFRS S2
Like: Building regulations
“Your building must have fire safety systems and you must document them.”
TPT Framework
Like: Fire safety engineering standards
“Here's exactly how to design, install, test, and document fire safety systems that meet the regulations.”
ISSB says what to disclose. TPT says how to build and disclose it credibly.
Why Do Multiple Frameworks Exist?
The transition plan landscape is fragmented because different organizations tackle different parts of the problem. Understanding their roles reduces confusion.
CDP (Carbon Disclosure Project)
Disclosure PlatformWhat:
Global disclosure system for environmental reporting (climate, water, forests)
Why:
Standardizes how companies report to investors and stakeholders
Output:
Annual CDP questionnaire responses and scores
ISSB (International Sustainability Standards Board)
Global Disclosure Standard SetterWhat:
Creates baseline sustainability disclosure standards (IFRS S1, S2)
Why:
Harmonizes sustainability reporting across jurisdictions
Output:
IFRS S2: Climate-related Disclosures
TPT (Transition Plan Taskforce)
Implementation Guidance DeveloperWhat:
Developed practical framework for transition plan structure and content
Why:
ISSB standards define requirements but not methodology
Output:
TPT Disclosure Framework (5 elements, sector guidance)
SBTi (Science Based Targets initiative)
Target Validation OrganizationWhat:
Validates corporate emissions reduction targets against climate science
Why:
Ensures targets align with 1.5°C pathway
Output:
Approved science-based targets
TNFD (Taskforce on Nature-related Financial Disclosures)
Nature Disclosure FrameworkWhat:
Framework for nature-related risk and opportunity disclosure
Why:
Climate and nature are interconnected systems
Output:
TNFD Recommendations
SBTN (Science Based Targets Network)
Nature Target MethodologyWhat:
Science-based target methodology for nature impacts
Why:
Provides rigor for nature commitments (like SBTi for climate)
Output:
Nature target guidance
How CDP, Target Setting, and Transition Plans Work Together
These aren't separate workstreams. They're an integrated system where each element reinforces the others.
CDP Disclosure
What it does: Provides the baseline. You report your current emissions, governance, risks, and progress through CDP's annual questionnaire.
Who sees it: Investors, customers, regulators. CDP scores become public benchmarks of climate performance.
Connection to transition plans: CDP asks if you have a transition plan and requests disclosure aligned with TCFD/TPT. Your CDP response becomes your public transition plan disclosure.
SBTi / SBTN Targets
What it does: Validates your destination. SBTi (climate) and SBTN (nature) ensure your targets align with 1.5°C pathways and nature-positive goals.
Who sees it: Targets are public commitments. Investors use SBTi validation as a credibility filter.
Connection to transition plans: Your transition plan operationalizes your SBTi/SBTN targets. The plan shows how you'll deliver what you've committed to.
Transition Plan (TPT)
What it does: Maps the route. Specific actions, capital allocation, governance, and timelines showing how you'll deliver your targets.
Who sees it: Disclosed through CDP, annual reports, or standalone transition plan documents. Investors evaluate credibility.
Connection to disclosure: Your plan feeds back into CDP responses annually. Progress (or lack of it) becomes visible through disclosure.
The Annual Cycle
Q1-Q2: Review prior year performance, update emissions baseline, assess progress vs targets
Q2-Q3: Refine transition plan based on what worked/didn't, adjust capital allocation, update timelines
Q3-Q4: Complete CDP disclosure including updated transition plan narrative and progress metrics
Q4-Q1: Investor engagement on results, identify gaps, feed insights back into next cycle
Global Regulatory Context
Different jurisdictions are implementing transition plan requirements at different speeds. Here's where the major markets stand.
United Kingdom
- • FCA: Listed companies must disclose against TPT or explain why not
- • TPR: Pension funds required to publish transition plans
- • Status: Moving from voluntary to mandatory
- • Timeline: Phased implementation 2024-2026
European Union
- • CSRD: Corporate Sustainability Reporting Directive
- • ESRS: European Sustainability Reporting Standards
- • Status: Mandatory for large companies
- • Alignment: Similar principles to TPT, ISSB interoperability
Global
- • ISSB adoption: Multiple jurisdictions adopting IFRS S2
- • TPT influence: IFRS ownership gives TPT global reach
- • Convergence: Frameworks aligning on core principles
- • Trend: Voluntary → comply-or-explain → mandatory
What This Means for You
1. Use TPT as Your Foundation
A transition plan built on TPT framework will meet ISSB requirements, travel across jurisdictions, and satisfy investor expectations. It's the de facto global standard.
2. Integrate Climate and Nature
Use TNFD and SBTN alongside TPT and SBTi. Climate-only plans are increasingly seen as incomplete. Nature integration is where regulation is heading next.
3. Get Targets Validated Early
SBTi-validated targets give your transition plan instant credibility. Without science-based targets, your plan lacks a validated destination. Start the SBTi process early.
4. Focus on Implementation Over Compliance
Don't get lost trying to comply with every framework perfectly. Build a credible plan that delivers real decarbonisation. Let implementation quality drive disclosure quality.
The goal isn't perfect compliance.
It's a credible plan that investors, regulators, and delivery teams can trust.