Trustee seeks halt on climate reporting rules

A trustee is calling for a moratorium on TCFD and implementation statements for pension schemes, citing that many reports are seen as “box‑ticking exercises”.

Bobby Riddaway, managing director of HS Trustees and founder chair of the Trustee Sustainability Working Group, made the comments in a column.

Reporting Burden

Some schemes spend up to £500,000 annually on these disclosures, with implementation reports often being “generic” and consuming a large share of consulting budgets. The cost pressure is felt especially by schemes that sit below the £100 million asset threshold, where the proportion of external advice devoted to compliance can eclipse the resources allocated to genuine climate mitigation projects. By channeling professional services into repetitive data collection, firms risk creating a cycle in which the same advisory firms are repeatedly hired to produce similar narrative sections, rather than being challenged to deliver new analytical tools or scenario testing.

Riddaway argues that this diverts resources from more impactful climate initiatives, leaving little room for proactive climate strategy. When staff are tasked with populating tables that satisfy regulatory checklists, the opportunity to explore innovative financing mechanisms—such as green bonds or blended‑capital structures—diminishes. Moreover, the emphasis on meeting disclosure deadlines can crowd out internal capability building, meaning that pension trustees may never acquire the technical fluency needed to assess climate‑related risk beyond the mandated metrics.

He believes that sustainability experts are often stuck in a reporting loop, rather than educating or innovating. This observation highlights a broader cultural issue within the industry: the perception that compliance is an end‑state rather than a stepping stone toward strategic change.

Refocusing Efforts

Riddaway suggests that a moratorium on TCFD and implementation statements would free up expert time for more valuable tasks, such as educating trustees and consultants. By halting the mandatory filing schedule, senior sustainability officers could redirect their attention toward workshops that demystify climate risk for board members, enabling a more subtle discussion of exposure, resilience, and opportunity. This shift would also create bandwidth for developing structured finance models that align long‑term asset allocation with net‑zero pathways, a capability that currently remains under‑utilised across many pension portfolios.

A moratorium would signal the government’s intent to prioritize action over compliance, and encourage collaboration between schemes, government bodies, and institutions. By aligning the regulatory narrative with the strategic objectives of bodies like the British Business Bank and the National Wealth Fund, the industry could benefit from a coordinated push toward capital deployment in low‑carbon technologies, rather than dispersing effort across fragmented reporting exercises.

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According to the report, such a move could empower sustainability experts to focus on solutions, not just disclosures. The empowerment comes from granting practitioners the discretion to allocate consultancy spend toward scenario analysis, stress‑testing of portfolio exposure, and the design of transition‑aligned investment mandates. When the emphasis moves from ticking boxes to delivering actionable insights, the downstream effect is a more resilient pension fund that can adapt to regulatory evolution without being caught off‑guard.

Long-Term Requirements

The government could then observe the industry’s success before deciding on long‑term requirements, which might include replacing TCFD with transition plans. Transition plans would require schemes to outline concrete pathways for decarbonising their holdings, moving the conversation from high‑level governance statements to measurable milestones and capital deployment targets. This evolution would also create space for smaller schemes to adopt proportionate reporting frameworks, reducing the administrative overhead that currently hampers their ability to participate in climate‑focused investing.

Riddaway also suggests simplifying implementation statements for small schemes, which could help reduce the reporting burden. Simplification could involve a tiered approach where assets under a certain threshold are required to provide a concise narrative rather than a full technical annex, thereby preserving the integrity of the disclosure regime while acknowledging the resource constraints of smaller trustees.

He notes that this approach would support a culture of proactive investment across the industry, and could lead to a short‑term surge in UK investment. By removing the immediate pressure to produce extensive reports, funds would be freer to allocate capital toward domestic renewable projects, energy‑efficiency retrofits, and climate‑resilient infrastructure, all of which have the potential to generate both financial returns and emissions reductions.

It’s worth examining how this proposal could impact the industry, and whether it could lead to long‑term growth in private markets, as Riddaway, that is, the author of the column, seems to think it could.

Ultimately, the goal is to unlock pension capital for the climate transition, and Riddaway’s proposal is one possible solution.