Hot weather events, ventilation assets, changing passenger demand and service expectations have all caused increased attention on thermal comfort on London’s Tube. This study provides estimates of the future number of days when passengers travelling on sections of the Tube could be subjected to thermal discomfort under future scenarios of climate change, and the potential number of passengers dissatisfied. A risk based methodology is presented, integrating a spatial weather generator modified for urban areas and a thermal comfort model. The study provides an initial assessment of adaptation options by considering the implications of lowering train temperatures by 2 °C and 4 °C to represent saloon cooling. Median results under a 2050 high scenario indicate that all Tube lines assessed could experience near-complete passenger dissatisfaction with the thermal environment in trains in the unlikely event that nothing else were to change. Adaptation aimed at lowering train temperatures has the potential to provide tangible improvements in thermal comfort. However, this was not projected to be sufficient to maintain comfortable thermal conditions for many of the lines in the 2050s under high emission scenarios, requiring a combination of other infrastructure cooling measures to be implemented in parallel.