News & Events

Back to articles


Changes to climate reporting for pension trustees

11th November 2022

The Pensions Regulator has updated its guidance on governance and reporting of climate-related risks for trustees of certain pension schemes, increasing the number of schemes the guidance now applies to.  Matt Hutchinson, head of Rowleys’ pensions team explains more about the pension climate change reporting requirements, the schemes it applies to and what might lie ahead for smaller schemes.


Guidance on climate-related risks

In 2021, new guidance was introduced that required trustees of authorised master trusts, and of larger schemes with a net relevant assets of £5 billion or more, to identify, assess and manage climate-related risks and opportunities. From October 2022, this has been reduced to schemes with assets of £1 billion.


Trustees of these schemes are required to measure and report on their portfolios’ alignment with the Paris Agreement on climate change. The Paris Agreement aims to limit the global average temperature increase to 1.5 degrees Celsius above pre-industrial levels. The aim of new requirements is to ensure trustees have an understanding of a scheme’s exposure to climate risk.


What are the recent changes and who do they apply to?

The Pensions Regulator (TPR) has recently amended the guidance and from 1 October 2022 the rules also apply to trustees of schemes with net relevant assets of £1 billion or more.


TPR state that they will will be looking for clear evidence that trustees:


Will smaller schemes be subject to these requirements in the future?

It is highly likely that, in the future smaller schemes will be subject to some sort of requirements related to climate change and climate-related risks.  The Department for Work and Pensions has already stated that it intends to consider whether to extend the current rules to smaller schemes in 2023, so it’s important trustees pay close attention to any updates from TPR about changes to the criteria.


With climate change being on the agenda of the world with COP27 currently taking place there is a clear direction of travel that is likely to affect all schemes in the future to some extent.  Past experience has shown that the introduction of similar reporting requirements initially applying to larger schemes later apply to smaller schemes, even if this is to a reduced requirement level.


For further information, visit The Pensions Regulator website.


The Rowleys pensions team are pension audit experts. We work with a large number of pension schemes, taking a balanced, risk-based approach to audit.  If you’d like to discuss your pension scheme accounts and audit requirements, then please get in touch.


Registered to carry on audit work in the UK; regulated for a range of investment business activities; and licensed to carry out the reserved legal activity of non-contentious probate in England and Wales by the Institute of Chartered Accountants in England and Wales.  Associate Directors of the firm are not Directors of The Rowleys Partnership Limited (registered no. 06125028) and are not subject to the obligations and responsibilities of Directors within Part 10 of the Companies Act 2006.  Any reference to an individual with the job title “Partner” refers to someone who is a Director of The Rowleys Partnership Limited and also a registered member of Rowleys Group LLP (registered no. OC306056)  A list of Directors and Members are available at Companies House. Details of our audit registration can be viewed at and details of our probate registration can be viewed at, both under reference number C001486455. View our Legal and Privacy PolicyView our Terms of Business