Asset Owner Reporting Tool updated to include TCFD Reporting Requirements

Asset Owner Reporting Tool updated to include TCFD Reporting Requirements

David Rusell and Dr Rory Sullivan

November 2021

In April 2021, USS, Brunel Pension Partnership, BTPS, the Church of England Pensions Board, Railpen, and Chronos Sustainability released a reporting tool to help asset owners meet their responsible investment and stewardship reporting requirements efficiently and effectively.

The tool focused on what we saw as the three most significant reporting obligations faced by UK pension funds, namely the UK Stewardship Code, the PRI’s Reporting and Assessment requirements and the Pension Regulator’s Implementation Statement. We have now reissued the tool, adding the requirements of the Taskforce on Climate-related Financial Disclosures (TCFD).

The reporting maps these four reporting requirements against each other, allowing users to identify, for example, which elements of the PRI’s reporting requirements may help meet the Stewardship Code reporting requirements. It also provides a checklist of reporting requirements, which can be used to assess the completeness of reporting.


The original tool has been used by a number of asset owners and asset managers to help guide their reporting and as a checklist on the completeness of this reporting. From our discussions with these users, it is clear that the reporting tool has helped them to both navigate the complex landscape of reporting and to have confidence in the completeness and adequacy of their reporting.


It is also clear, both from the reporting tool itself and from asset owners and asset managers grappling with the many different reporting requirements that they face, that reporting is burdensome and that there are relatively few efficiencies to be gained. While there are often commonalities on data and indicators, there is inevitably a large amount of additional writing and text editing involved in preparing submissions.


One of the priorities for the asset owners that supported the development of the reporting tool is exploring how they can efficiently and effectively provide comprehensive reporting on their approaches to responsible investment and stewardship that meets the needs of their stakeholders while also meeting the formal reporting requirements that they face.

This reporting tool is one part of that process, providing the analytical basis for asset owners’ discussions with policymakers, industry bodies and other stakeholders on reporting.


The reporting tool can be found here.



David Russell is Head of Responsible Investment at USS Investment Management and Dr Rory Sullivan is CEO at Chronos Sustainability