NHS organisations must make annual TCFD disclosures: Here is what you need to know

The end of the financial year in March 2026 also marked the end of the three-year phased implementation of Task Force on Climate-related Financial Disclosures (TCFD) aligned reporting for NHS organisations.

Now NHS bodies in England with more than 500 full-time equivalent employees or a total operating income of more than £500m (which is the case for all NHS foundation trusts) must make TCFD-aligned disclosures as part of their annual report.

However, many organisations have not implemented this reporting yet or their disclosures don’t meet the TCFD requirements.

What is the latest?

From 2025/26 entities should disclose how the organisation’s operations, strategy and financial planning are affected by actual and potential climate-related risks and opportunities.

Where external reports, such as NHS Green Plans, contain relevant information for the recommended disclosures, entities are not required to duplicate this information in this part of the annual report but can cross-reference to compile these TCFD disclosures.

What are the key areas of TCFD reporting?

• Governance: Your governance around climate-related risks and opportunities, such as board oversight and the role of management in managing these.
• Strategy: Actual and potential impacts of climate-related risks and opportunities on your organisation, strategy and financial planning.
• Risk Management: How the organisation identifies, assesses and manages climate-related risks.
• Metrics and Targets: The metrics and targets used to assess and manage relevant climate-related risks and opportunities.

How can Inspired help?

NHS organisations continuously manage competing demands, along with funding and resource limitations and continuously evolving compliance and reporting demands.

Further expectations requiring specialised information, such as TCFD-aligned disclosures or updated NHS Green Plan requirements, can understandably place further pressure on your internal resources.

With a combination of extensive sustainability expertise and a firm understanding of the public sector and healthcare environment, Inspired can bolster your internal resources while steering you through the intricacies of creating compliant disclosures.

TCFD-aligned reporting for your NHS organisation

Inspired offers a comprehensive TCFD service that covers all your climate-related financial reporting needs. Our experts will:

• Review and enhance your ESG governance structures.
• Conduct in-depth climate-related scenario analyses to pinpoint essential risks and opportunities.
• Help develop comprehensive mitigation plans based on these insights.
• Refine your climate-related metrics and targets to ensure transparency and accountability.

Green Plans

Information submitted as part of your NHS Green Plan bolsters your TCFD disclosures. Moreover, the Green Plan guidance has recently been revised.

Inspired supports NHS trusts, integrated care systems and other NHS bodies to develop and update Green Plans that align with national guidance, local priorities and operational realities.

Whether you are developing your first Green Plan or refreshing an existing one, we offer bespoke support to create a robust, current and achievable plan. Our experts will:

• Calculate your complete Scope 1, 2, and 3 carbon footprint (NHS Carbon Footprint and NHS Carbon Footprint Plus).
• Track your progress against set actions and targets.
• Formulate a forward-looking decarbonisation strategy, aligned to the NHS best practice.