CSRD reporting requirements for UK companies in scope

Only an entity the CSRD reaches has them: an EU subsidiary or EU parent group above the thresholds, an issuer on an EU regulated market, or, from financial year 2028, an EU subsidiary or branch publishing a non-EU group’s report under Article 40a.

The in-scope entity produces a sustainability statement in a dedicated section of its management report, prepared to the ESRS, in the single electronic reporting format, with a limited assurance opinion.

Where the UK company is inside an EU group’s statement, it supplies data rather than reporting itself.

The revised ESRS, Delegated Regulation (EU) 2026/1563, apply to financial years beginning on or after 1 January 2027, so first reports under them appear in 2028.

For financial years starting in 2026 there are three options — the 2023 standards as last amended by Delegated Regulation (EU) 2025/1416, the revised standards in full, or the 2023 standards with eight named reliefs — and the statement must say which was used.

Not until 10 November 2026.

They were adopted on 3 July 2026 and published in the Official Journal on 21 September 2026 as Delegated Regulation (EU) 2026/1563.

Even after 10 November nothing in them is required before a financial year beginning on or after 1 January 2027.

The voluntary standard, Delegated Regulation (EU) 2026/1560, has been in force since 24 September 2026.

No. CSRD assurance is limited assurance.

Omnibus I removed the Commission’s power to adopt reasonable assurance standards, so there is no legislated move to reasonable assurance.

The Commission must adopt the limited assurance standards by 1 July 2027, moved from 1 October 2026.

By default the statutory auditor of the financial statements.

A Member State may also allow a different statutory auditor or audit firm, and may allow an independent assurance services provider under equivalent requirements.

Because the wider options are national choices, a group with subsidiaries in several Member States can have different answers in each.

Not under the revised ESRS.

ESRS 1 ¶24 says the undertaking shall not disclose information prescribed by a disclosure requirement or datapoint if it is not material.

A statement padded with immaterial disclosures in an earlier year needs a removal pass, with the materiality assessment as the authority for each removal.

Yes.

The sustainability statement carries the Article 8 Taxonomy disclosures, and the assurance opinion covers compliance with Article 8.

The revised ESRS let Taxonomy content sit in a separate appendix, which is a presentation relief, not a scope relief: it stays inside the opinion.

When EUR-Lex’s national transposition list was re-read on 11 September 2026, four had notified measures — Belgium, Croatia, Poland and Finland — and the other twenty-three showed none.

Nobody is late: the deadline for Articles 1 to 3 is 19 March 2027.

The revised ESRS need no transposition, because a regulation applies directly.

No. None discharges another.

The CSRD asks for an ESRS statement on double materiality with limited assurance.

UK SRS, under the FCA’s final rules, asks listed companies to report against UK SRS on a comply-or-explain basis, on financial materiality.

SECR is annual energy and carbon reporting in the directors’ report under UK company law.

One emissions inventory can feed all three.

For financial years beginning on or after 1 January 2028, with first reports in 2029.

The turnover test looks back two years, so 2026 and 2027 decide it.

The report will be written to ESRS-40a, which exists only as an exposure draft, with consultation to 31 October 2026 and EFRAG’s technical advice due in January 2027.

More than €450 million of net turnover and an average of more than 1,000 employees during the financial year, both at once.

The old two-of-three test is gone, and the 1,750-employee figure that circulated before the adopted text is wrong.

For a non-EU group, Article 40a asks for more than €450 million of EU net turnover in each of the last two years plus an EU subsidiary or branch above €200 million.

The Commission says over 60% of mandatory datapoints and more than 70% of all datapoints.

EFRAG’s own figure for its draft is 61% of mandatory datapoints and 71% including voluntary ones.

The difference is that every voluntary datapoint was deleted.

Avoid absolute counts: the widely quoted 1,144 is a total count of a 2022 draft, not a baseline for either percentage.

It stops an in-scope company requiring a protected undertaking — one not exceeding an average of 1,000 employees in the preceding financial year — to provide more sustainability information, for CSRD reporting, than the voluntary standard specifies.

A customer may rely on a self-declaration of size unless it is manifestly incorrect.

It stops customers requiring more, not asking, and it does not reach commercial due diligence or financing terms.

In reduced form.

There is no anticipated-financial-effects disclosure requirement left in ESRS E2 to E5; what survives sits in ESRS 2 and ESRS E1-11.

The revised ESRS 1 ¶125 lets undertakings omit that information for financial years before 2028, and the quantitative part for years before 2030, except for named paragraphs of E1-11.

No. The revised ESRS are a Commission delegated regulation, directly applicable in every Member State.

What needs transposing is Omnibus I, the directive that changed scope, assurance and the value-chain cap, by 19 March 2027 for its Articles 1 to 3.

Omnibus I limits the first-wave obligation to financial years 2024 to 2026.

From financial years starting on or after 1 January 2027 the second-wave test applies to everyone: an entity above €450 million of net turnover and an average of 1,000 employees stays in and moves to the revised ESRS; one below falls out, and its Member State may exempt it for 2025 and 2026.

It is part of the management report, so it is approved through whatever process the in-scope entity’s Member State law sets for that report.

The limited assurance opinion is given by the statutory auditor by default, or by another provider where the Member State allows.

Every statement includes the general disclosures in ESRS 2 — basis of preparation, governance including internal controls over sustainability reporting, strategy and business model, and the materiality process and its results — and then the topical standards the double materiality assessment found material, for the material sub-topics only, plus the Taxonomy Article 8 disclosures.

No official template prescribes the layout.

The ESRS set the content, ESRS 2 allows a content index of the disclosure requirements met, and the statement is marked up in the single electronic reporting format.

The structure follows ESRS 2 and then the material topics.

Yes, under Article 19a(9) of the Accounting Directive, where the subsidiary is included in the UK parent’s consolidated sustainability reporting prepared under the ESRS or an equivalent standard, and conditions are met, including publishing that reporting, its assurance opinion and the Taxonomy disclosures.

A UK SRS report is not ESRS reporting.

GOV-4 requires a description of the scope, main features and components of the undertaking’s risk management and internal control processes and systems over sustainability reporting.

Its application requirement points to the completeness and integrity of data and the accuracy of estimates.

In a dedicated section of the management report of the in-scope undertaking, and so on the timetable and through the filing route its Member State sets for the management report.

For an Article 40a report, the EU subsidiary or branch publishes it.