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Transition Plan – Consultation Response

September 24, 2025

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We submitted evidence last week to the government’s long-awaited consultation on transition plan requirements. These requirements are a vital step in aligning finance with climate and nature goals. If implemented ambitiously, they can drive investment into climate and nature solutions and strengthen financial resilience. But the policy risks falling short if requirements are weakened and systemic climate risks are overlooked in policy design.

In our response, we recommend that transition plans should be:

  • Embedded as a core part of corporate strategy and culture
  • Mandatory (not ‘comply or explain’) and science-based
  • Built around long-term goals with interim targets anchored in the Paris Agreement, alongside disclosure of dependencies and external factors
  • Aligned with TPT guidance to support credible adoption and international alignment
  • Integrate nature from the outset
  • Scoped in a proportionate and progressive way, drawing on the phased TCFD model.

We look forward to supporting the consultation outcomes in the months ahead and working with partners, government and industry to promote ambitious and credible implementation. Onwards!

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