Schemes with relevant assets of £5bn or more on the first scheme year-end date to fall on or after 1 March 2020 must meet the climate change governance requirements for the current scheme year. Schemes with £1bn or more assets have an additional 12 months to comply.

The new requirements do not affect financial reporting disclosures but do have an impact on the information included in (and linked from) the annual report of occupational pension schemes.

A review of the disclosure rules for smaller schemes with assets worth less than £1bn will now take place in the second half of 2023.

The disclosures cover four core areas – governance, strategy, risk management, and metrics and targets. Trustees must establish and maintain oversight of the climate-related risks and opportunities which are relevant to the scheme.