6.01 The 2024 climate resilience analysis names two different sets of climate scenarios and calls 2030 both short and medium term
UK Company A · a UK-listed medical technology group · Presentation point
In brief
The physical risks table says the scenario modelling used the IPCC scenarios SSP1-[n], SSP2-[n] and SSP3-[n]. Two pages later the resilience paragraph says the same stress test used RCP [n], RCP [n] and RCP [n], and points back to that table. The same paragraph calls the horizon to 2030 'short-term', while the time-horizon definitions say scenario modelling to 2030 is medium term. A reader cannot tell which high-warming scenario was run or which horizon the 2030 results belong to.
The evidence, as filed
Screenshot withheld to protect the company’s identity: Annual Report 2024, page 71; Annual Report 2025, page 72; Annual Report 2024, page 72; Annual Report 2024, page 73. Their wording or layout could lead back to the company even with names and figures masked; the evidence list below records what each page shows.
What the report shows, and what the rule requires
| What the annual report shows | What the rule requires |
|---|---|
| What the annual report shows Physical risks table: SSP1-[n], SSP2-[n] and SSP3-[n] (High: limit warming to 4°C). Resilience paragraph: RCP [n], RCP [n] and RCP [n], used '[wording masked]', with 'short-term (by 2030)'. Time horizons: medium term [wording masked] 2030'. | What the rule requires One description of the scenarios actually run for the resilience analysis (either the SSP set or the RCP set, or both with the mapping between them), and the 2030 horizon labelled the same way as the stated time-horizon definitions. |
What we checked: Physical risks table, strategy and resilience paragraphs, risk-management time horizons in the 2024 report; the same section of the 2025 report
The rule
Companies Act 2006 s.414CB(2A)(f)
Version relied on: Companies Act 2006, revised text on legislation.gov.uk as in force for the financial year reviewed
an analysis of the resilience of the company’s business model and strategy, taking into consideration different climate-related scenarios
Companies Act 2006 s.414CB(2A)(d)(ii)
Version relied on: Companies Act 2006, revised text on legislation.gov.uk as in force for the financial year reviewed
the principal climate-related risks and opportunities arising in connection with the company’s operations, and (ii) the time periods by reference to which those risks and opportunities are assessed
Why it applies here: the high-warming scenario is SSP3-[n] in the table but RCP [n] in the text; these are different pathways with different radiative-forcing levels, so the two descriptions cannot both describe the same run.
Why it matters
The required resilience analysis does not say clearly which scenarios were run or which horizon its 2030 results belong to, which weakens the reader's ability to judge the climate stress test and could draw a Corporate Reporting Review enquiry.
Exposure
In practice an FRC Corporate Reporting Review enquiry letter and an undertaking to improve the next report; no fine is realistic for a description inconsistency.
Our workings
the physical risks table on p.71 lists Low SSP1-[n], Medium SSP2-[n] and High SSP3-[n]. The strategy text on p.72 says the resilience of the strategy was considered for three scenarios, RCP [n], RCP [n] and RCP [n], and that the scenarios described were used [wording masked], pointing to the table on the earlier pages. The same sentence calls the 2030 horizon 'short-term (by 2030)'. P.73 defines medium term as [wording masked] 2030'.
The 2030 horizon is short term on one page and medium term on the next. The analysis of resilience under different scenarios is a required climate-related financial disclosure, so its description should be internally consistent. The 2025 report keeps only the SSP list and drops the RCP paragraph, which suggests the table is the correct description.
| Page | Scenarios named | 2030 horizon called |
|---|---|---|
| p.71 physical risks table | SSP1-[n], SSP2-[n], SSP3-[n] | no label |
| p.72 resilience paragraph | RCP [n], RCP [n], RCP [n] | short-term (by 2030) |
| p.73 time horizons | none | medium term, [wording masked] 2030 |
Management’s best defence, and our reply
The company could say that the shared socio-economic pathways build on the representative concentration pathways, so the low and medium scenarios describe the same forcing levels under either name, and that 'RCP [n]' was used loosely to mean the high-emissions case. It could also say the 2030 label is plain-language shorthand and that the conclusion - no material impact on resilience - is the same under either description. However, SSP3-[n] and RCP [n] are different pathways with different forcing levels, the paragraph says expressly that it used the scenarios in the table, and the time-horizon definitions on the next page put 2030 in the medium term; the description cannot be right on both pages. The company's own 2025 report removed the RCP paragraph, which supports the point.
The fix
- Describe the resilience analysis once, for example: 'We tested resilience under three IPCC sixth assessment scenarios - SSP1-[n], SSP2-[n] and SSP3-[n] - to 2030 (medium term) and [n] (long term)', and remove the RCP list (done in the Annual Report 2025).
Evidence relied on
| # | What it shows | Type | Where |
|---|---|---|---|
| 1 | The physical risks table names the SSP scenarios that were modelled | Document | Annual Report 2024, page 71 |
| 2 | The resilience paragraph labels the 2030 horizon short-term | Document | Annual Report 2024, page 72 |
| 3 | The resilience paragraph names RCP [n] as the first scenario | Document | Annual Report 2024, page 72 |
| 4 | The resilience paragraph names RCP [n] as the second scenario | Document | Annual Report 2024, page 72 |
| 5 | The resilience paragraph names RCP [n] as the high scenario, where the table names SSP3-[n] | Document | Annual Report 2024, page 72 |
| 6 | The paragraph says the same scenarios were used for the stress test and points to the table on the earlier pages | Document | Annual Report 2024, page 72 |
| 7 | The time-horizon definitions place scenario modelling to 2030 in the medium term | Document | Annual Report 2024, page 73 |
| 8 | The 2025 report keeps the SSP list in the same table and no longer carries the RCP paragraph | Document | Annual Report 2025, page 72 |
Prepared by Pramanex from the company’s published annual reports, without the company’s involvement, to show how an annual report review reads. The company is not named, and nothing on this page is a statement about any identifiable company. Observations are not an audit, review or other assurance engagement, and not legal advice. A regulator-style question is a question, not a conclusion.
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