What the government’s new climate disclosures tell us about risks to public services

This post is by Harriet Phillips, senior audit manager at the National Audit Office.

We often talk about climate risk as a future problem, but – as, after this summer, everyone knows – climate change is already having a significant impact on public services.

The National Audit Office’s (NAO’s) report, Government’s climate risk: insights from 2025-26 disclosures, explores a developing source of information: climate-related disclosures in public bodies’ annual reports. Here are three things this reporting has revealed, and some important gaps in the picture.

It’s a new window into government resilience More than 100 organisations in central government now have to explain whether climate change is a significant risk to them, and if so how this will affect them, including their finances. Rather than national outcomes, this new reporting requirement shines a light on the exposure of individual organisations to climate risk and what they are doing about it. The NAO reviewed the Task Force on Climate-related Financial Disclosures (TCFD) reports of 31 government bodies. These were selected for their probable exposure to climate risks, rather than because they are representative of the government. However, together, they offer a snapshot of the government’s resilience to climate change.

Flooding and heat are already disrupting public services Flooding was the most commonly identified climate risk in the sample. Eighty nine per cent of prisons are at high or very high risk of flooding, while NHS England reported just under 400 flooding incidents at NHS sites in 2024-25 and the Environment Agency issued nearly 1,000 flood warnings in 2025-26. Separately, the Department for Education (DfE) has published estimates that 38 per cent of secondary schools and 33 per cent of primary schools are at high risk of flooding.

Overheating was another common concern, identified by over half of the sample. Potential consequences included damaged buildings, disrupted services, and worsening conditions for staff and service users. For example, 76 per cent of courts and 71per cent of prisons were at high risk of overheating from summer temperatures. Heatwaves increase the likelihood of prison violence.

Importantly, these risks are already having an impact. Flooding and overheating are causing disruption in services, for example in delays to patient care. These are set to increase even in a low greenhouse gas emissions scenario. The DfE estimates that up to 6.7 “learning days” are lost in schools at present. This reflects decreased ability to learn in warmer temperatures over the course of the year in buildings designed for a cooler climate. NHS England reports the estimated additional cost of heat-related mortality at £6.8 billion a year in the 2020s alone.

Under a third of organisations had quantified the costs Several organisations identified significant potential future impacts in a high greenhouse gas emissions scenario. For example, Northern Trains reported that with four degrees of warming, some coastal train routes would become inoperable or financially unviable due to rising sea levels.

Nobody can predict the future. However, even limited climate scenario analysis can help organisations prepare for a range of outcomes. It can help identify opportunities to build in resilience and weigh up present investment costs against future potential impacts.

For example, HM Prison and Probation Service identified the 2030s as a challenging decade across all its scenarios, as increasing physical impacts of climate change will coincide with peak transition investment. It plans to use this analysis in its property investment planning. Similarly, the Environment Agency used scenario analysis to restructure its incident response service. This was fast becoming operationally and financially unsustainable due to rising levels of demand.

Such examples are not yet typical. Only a third of central government bodies required to provide strategy disclosures completed them in full. Others explained these omissions, under Treasury’s ‘comply or explain’ approach. Just nine of the 31 organisations in the sample were able to quantify the costs of climate change on their business.

Measuring exposure is not the same as measuring progress TCFD reporting asks organisations to disclose the key metrics and targets they are using to manage climate related risk. Of 15 central government organisations required to provide this reporting, only ten provided a relevant climate risk metric and just five set a target. Many metrics described exposure to hazards, rather than how effectively risks were being managed.

This reporting is useful because it shows how organisations are managing their risks in practice. Target setting is difficult, as a useful target needs to be a meaningful indicator of progress. To set a target you need to understand the risk, your ability to influence the outcome and a realistic expectation of what you can achieve.

Reporting improvements are encouraging For many government bodies TCFD reporting is a work in progress, although the review found encouraging improvements in governance and risk management reporting. The next challenge is to connect those arrangements to clearer accounts of impacts, costs and results. Three questions offer a useful starting point: what is at risk, who is responsible and what evidence shows the response is working?