FCA Consultation Paper CP26/5: Aligning listed issuers' sustainability disclosures with international standards

We refer to the Financial Conduct Authority’s Consultation Paper CP26/5 on aligning listed issuers’ sustainability disclosures with international standards, published on 30 January 2026. We welcome the opportunity to contribute an investor perspective on the FCA’s proposals to update the UK Listing Rules.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank (Norges Bank) and is responsible for investing the Norwegian Government Pension Fund Global. NBIM is a globally diversified investment manager with approximately 21,300 billion Norwegian kroner under management. Of these, about GBP 80 billion was invested in the United Kingdom at year end 2025.

As a long-term, global investor, we consider our returns over time to be dependent on sustainable development in economic, environmental and social terms, as well as on well-functioning, legitimate and efficient markets. We need consistent, comparable, reliable and decision-useful information from companies on sustainability-related risks and opportunities that are financially material to their business. This information informs our investment decisions, risk management processes and ownership activities. As a global investor, we have a clear interest in this information being reported in a consistent and comparable manner across markets.

We support the IFRS Sustainability Disclosure Standards (ISSB standards) as the global baseline of investor-focused standards for sustainability-related financial disclosures that are connected and complementary to financial statements. This is critical for us to formulate a holistic view of a company’s performance and prospects over time and facilitates cross-border capital flows. The ISSB standards also share the same conceptual foundations as the International Accounting Standards Board (IASB) financial reporting standards. Investors will be able to receive sustainability-related financial information that is concurrent, connected and complementary to financial statements. 

We therefore strongly support the FCA’s proposal to replace the existing TCFD-aligned listing rules with requirements referencing the UK Sustainability Reporting Standards (UK SRS). Aligning the UK’s disclosure framework with the ISSB standards is an important step towards improving the quantity, quality and comparability of sustainability-related financial information available to investors in the UK’s listed markets. We have previously encouraged the UK to endorse the ISSB Standards, having previously welcomed the TCFD-aligned requirements but noting the higher granularity and broader scope of IFRS S1 and S2. However, we have concerns about certain aspects of the proposals that risk undermining the completeness, comparability and decision-usefulness of the information that global investors need. We summarise our key messages below and provide detailed responses to selected consultation questions in the Annex.

Scope 3 emissions should become mandatory after the transition period. Scope 3 can represent 40%+ of total emissions and is material for assessing transition risk. UK SRS S2's proportionality provisions — estimation, tiered measurement, and the "reasonable and supportable information without undue cost or effort" standard — already address preparedness concerns, and the materiality lens means immaterial disclosures can be omitted. An indefinite "comply or explain" risks widespread non-reporting. We recommend mandatory Scope 3 reporting for periods beginning on or after 1 January 2028, or at minimum a clear sunset date for transition to mandatory disclosure. Allowing for longer transition reliefs for Scope 3 reporting rather than an indefinite “comply or explain” approach would also be in line with the decision taken by other jurisdictions, including some where climate-related reporting has been voluntary so far and/or less mature than in the UK.

UK SRS S1 should also have a clear mandatory reporting timeline. Non-climate sustainability information is equally capable of being financially material, a two-year transition relief is already built in, and voluntary disclosure rates among UK listed companies are already significant. An open-ended "comply or explain" regime provides insufficient certainty for preparers or investors. We therefore encourage the FCA to set a date by which reporting under UK SRS S1 will become mandatory, rather than leaving “comply or explain” as an open-ended regime.

Secondary-listed companies should not face weaker requirements than today. The proposed exemption for secondary-listed issuers and depositary receipt issuers risks reducing disclosure relative to current TCFD rules. We recommend requiring these issuers to report under ISSB Standards where not already subject to equivalent home-jurisdiction requirements, strengthening ISSB's role as a global reporting passport.

On transition plans and assurance, we support the FCA's proposals and welcome the reference to IFRS Educational Material based on Transition Plan Taskforce outputs. On assurance, we encourage the FCA to introduce mandatory requirements over time — beginning with GHG data, with a post-implementation review as a practical first step.

Please find our detailed responses to selected consultation questions in the Annex to this letter. We thank you for considering our perspective and remain at your disposal should you wish to discuss these matters further.

Yours sincerely

Carine Smith Ihenacho                                                                   
Chief Governance and Compliance Officer                     

Elisa Cencig            

Head of Policy Engagement