In our March review we set out general findings from the first year of annual climate change reporting, including areas for improvement and examples of good practice.

We have been clear that trustees should use the review to help prepare future reports.

Now, with more schemes having been brought into scope of reporting rules, we are evolving our regulatory approach.

Any failure to publish a report on a publicly available website within seven months of the relevant scheme year end is subject to a mandatory fine of at least £2,500.

And, where trustees have not complied with the Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021 more generally, we may issue a separate penalty of up to £50,000.

We will not shy away from imposing a penalty where it is right to do so.

Over the course of 2023 to 2024, we will review a cross section of reports to identify
good practice and areas for improvement.

We will scrutinise reports for compliance and expect the quality of reports to improve year on year as knowledge and practice evolves.

We will communicate the findings from our review as part of an industry-wide statement in 2024, which we expect trustees to use to inform and improve future reports.

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