Press release
UK government announces consultation on mandatory transition plans – ClientEarth reacts
25 June 2025
The UK government has today announced a consultation on mandating transition plan disclosure for UK-regulated financial institutions and FTSE 100 companies [1]. The consultation marks a crucial step towards ensuring the UK economy is ready for the challenges and opportunities of the net zero transition.
The announcement arrives in the same week as the publication of new legal opinion by barristers at Erskine Chambers addressing concerns that transition plans heighten corporate legal risk [2]. The opinion concluded:
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A regulatory requirement for companies to disclose a transition plan is not likely to result in materially heightened liability risk for companies or their directors;
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There are likely to be legal advantages for directors and companies from disclosing a well-prepared transition plan;
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From a liability perspective, there is no need to introduce new legal ‘safe-harbours’ for transition plan disclosure; and
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There are clear steps directors and companies can take to minimise the risk of liability in respect of transition plan disclosures.
Robert Clarke, Senior Lawyer at ClientEarth said:
“This consultation presents an opportunity for the UK to develop a robust transition planning regime. Getting it right will reward the UK with a policy that delivers clear upsides for the transition finance market, for climate integrity, and for corporate climate action."
"The announcement arrives in the same week as the new legal opinion which offers timely clarity that the disclosure of a well-prepared transition plan does not materially increase legal risk and offers legal benefits for companies and their directors. The opinion explains how longstanding legal standards would apply to transition plan disclosures and concludes that, from a liability perspective, additional ‘safe harbours’ are not required.”
"This is a chance to move past misplaced liability concerns and introduce effective tools to drive private sector climate action. We urge the Government to take this analysis into account as the rules are developed further.”
ENDS
Notes to editors:
[1] Gov.uk: Climate-related transition plan requirements https://www.gov.uk/government/consultations/climate-related-transition-plan-requirements
[2] Transition plan disclosure a climate and market imperative, not a legal trap, say lawyers https://www.clientearth.org/latest/press-office/transition-plan-disclosure-a-climate-and-market-imperative-not-a-legal-trap-say-lawyers/
About ClientEarth
ClientEarth is a non-profit organisation that uses the law to create systemic change that protects the Earth for – and with – its inhabitants. We are tackling climate change, protecting nature and stopping pollution, with partners and citizens around the globe. We hold industry and governments to account and defend everyone’s right to a healthy world. ClientEarth teams in Europe, Asia and the USA work to shape, implement and enforce the law, to build a future for our planet in which people and nature can thrive together.