Sustainability disclosure · what is in force now
What are the current sustainability disclosure requirements in the UK?
In force today: SECR energy and carbon reporting, climate-related financial disclosure, the section 172(1) and non-financial statements, pension scheme climate reports, and the FCA’s SDR regime with its anti-greenwashing rule.
UK SRS is voluntary until 1 January 2027, when five listing categories begin reporting against it or explaining why not.
Companies
What must a UK company disclose today?
Energy and carbon under SECR, and above 500 employees the eight climate disclosures.
SECR has applied to financial years beginning on or after 1 April 2019 (SI 2008/410 Sch 7).
An unquoted company is in scope when it exceeds two of £36m turnover, £18m balance sheet and 250 employees (¶20B); a large LLP reports under SI 2008/1911.
A company that used 40,000 kWh or less in the period need not give the figures, but must say so.
The climate-related financial disclosures in s.414CB(2A) cover governance, how risks and opportunities are identified and managed, their effect on the business model and strategy, scenario analysis, targets and KPIs.
Every paragraph is on SECR reporting requirements and CFD reporting requirements.
- 1
Directors’ report: SECR
Energy use, emissions, an intensity ratio, methodology and efficiency actions.
- 2
Strategic report: section 172(1)
How directors had regard to stakeholders and the environment.
- 3
Strategic report: climate
Eight disclosures, for named companies with more than 500 employees.
- 4
Website: modern slavery statement
At £36m turnover, signed and linked from the homepage.
The FCA’s SDR
What are the FCA’s Sustainability Disclosure Requirements?
A regime for investment firms: labels, naming rules, product disclosures and an anti-greenwashing rule for every authorised firm.
“Sustainability Disclosure Requirements” is also the name of a specific FCA regime, and it is easy to confuse with company reporting.
SDR reaches asset managers and their funds; its anti-greenwashing rule reaches every FCA-authorised firm, applying from 31 May 2024 (FCA).
An ordinary trading company is not inside SDR.
The rules in full are on SDR reporting requirements and FCA SDR and the anti-greenwashing rule.
FCA SDR
Anti-greenwashing rule
FCA SDR
Four labels
By status
Which requirements are in force, and which are not yet?
Filter thirteen requirements by status: in force, comply or explain, made but not yet applying, voluntary or proposed.
Status
Showing 13 of 13
| Requirement | Who | What | When |
|---|---|---|---|
| SECR energy and carbon | Quoted companies; unquoted companies and LLPs exceeding two of £36m, £18m and 250 staff | Energy use, emissions, an intensity ratio and efficiency actions in the directors’ report | Since April 2019 |
| Climate-related financial disclosure | Traded companies, banks, insurers, AIM companies and companies over £500m turnover, with more than 500 employees | Eight disclosures on governance, risks, scenarios, targets and KPIs in the strategic report | Since April 2022 |
| Section 172(1) statement | Companies above the medium-sized test | How directors had regard to stakeholders, the community and the environment | Strategic report |
| Non-financial and sustainability information statement | Traded, banking and insurance companies with more than 500 employees | Environmental, employee, social, human rights and anti-bribery matters | Strategic report |
| Anti-greenwashing rule | Every FCA-authorised firm | Sustainability references fair, clear and not misleading | Since 31 May 2024 |
| SDR labels and product disclosures | Asset managers and their funds | Labels are optional; using one without qualifying breaches the rule | FCA ESG sourcebook |
| Pension scheme climate report | Schemes with £1bn or more in assets, and authorised master trusts | A published climate report | SI 2021/839 |
| ESOS, modern slavery, gender pay gap | Large undertakings; £36m turnover; 250 employees | An energy audit notification, a website statement, six pay figures | Each its own instrument |
| UK Corporate Governance Code | Companies with a commercial companies listing | Report against the Code or explain | In force |
| UK SRS S1 and S2 (FCA rule) | UKLR 6, 14, 15, 16 and 22 | Report against UK SRS or explain what is missing and why | Periods from 1 January 2027 |
| ESG ratings regulation | Providers of ESG ratings | Providing a rating becomes a regulated activity | 29 June 2028 |
| UK SRS for everyone else | Any entity | Voluntary use of S1 and S2 | Since 25 February 2026 |
| Modernising Corporate Reporting | Companies preparing annual reports | Restructure the annual report; move SECR | Consultation closes 30 November 2026 |
Status on the date this page was last checked, shown at the foot.
Each row is cited in the sources below; every regime is on the sustainability reporting requirements page.
Listed companies
What changes for listed companies from 2027?
UK SRS on comply or explain, with reliefs in the first two years.
Under PS26/19, companies in UKLR 6, 14, 15, 16 and 22 report against UK SRS S1 and S2, or explain, for accounting periods beginning on or after 1 January 2027.
Until then they continue under the climate-related listing rules; the move is set out on TCFD to UK SRS.
The FCA’s rule is not a mandate: the end of the reliefs leaves comply or explain in place.
What starts next
Which sustainability disclosure dates come next?
The consultation closes in November 2026, UK SRS periods begin in January 2027, and ESG ratings are regulated from June 2028.
- 30 November 202601
- 1 January 202702
UK SRS periods begin for five listing categories
Comply or explain, with a one-year Scope 3 relief and a two-year climate-first relief. - 202803
- 29 June 202804
Every date in the cluster is on the UK sustainability regulation timeline.
Today’s duties are carbon and climate in the annual report, and UK SRS joins them for five listing categories from 2027.
- In force since 2019
SECR puts energy and carbon in the directors’ report
For quoted and large unquoted companies. - More than 500 employees
Eight climate disclosures go in the strategic report
For named categories of company. - 31 May 2024
The anti-greenwashing rule binds every FCA-authorised firm
Part of the SDR regime. - 1 January 2027
UK SRS applies on comply or explain to five listing categories
Voluntary for everyone else.
Frequently asked
Current sustainability disclosures, answered
What are the current sustainability disclosure requirements in the UK?
The requirements in force are SECR energy and carbon reporting, climate-related financial disclosure for companies with more than 500 employees in named categories, the section 172(1) and non-financial statements, pension scheme climate reports, the FCA’s SDR regime for asset managers and its anti-greenwashing rule for every authorised firm, plus ESOS, the modern slavery statement and gender pay gap reporting.
UK SRS is voluntary until the FCA’s comply-or-explain rule applies to periods beginning on or after 1 January 2027.
What is the FCA’s Sustainability Disclosure Requirements regime?
SDR is the FCA’s package for investment firms: four sustainability labels for funds, naming and marketing rules, consumer-facing and detailed product disclosures, and an anti-greenwashing rule that applies to every FCA-authorised firm from 31 May 2024. It is not a reporting duty for ordinary companies.
Does the anti-greenwashing rule apply to every company?
It applies to every FCA-authorised firm, not to every company.
ESG 4.3.1R requires references to the sustainability characteristics of a product or service to be consistent with them and fair, clear and not misleading.
Other businesses’ green claims are governed by consumer protection law and the CMA’s Green Claims Code.
What does SECR require a company to disclose?
UK energy use, the associated greenhouse gas emissions, at least one intensity ratio, the methodology, prior-year figures and the principal energy efficiency measures taken.
A quoted company reports global Scope 1 and 2 emissions.
A company using 40,000 kWh or less in the period need not disclose the energy and emissions figures, but says so.
Are UK SRS disclosures required now?
No. UK SRS S1 and S2 were published on 25 February 2026 for voluntary use.
The FCA’s comply-or-explain rule applies to companies in UKLR 6, 14, 15, 16 and 22 for accounting periods beginning on or after 1 January 2027, so the first reports are published in 2028.
Is the Modernising Corporate Reporting consultation a current requirement?
No. It is a consultation that closes on 30 November 2026.
It proposes to restructure the annual report and move SECR out of the directors’ report.
None of it applies until legislation is made.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- legislation.gov.ukSI 2008/410, Schedule 7 (SECR)
Energy, emissions, an intensity ratio and efficiency actions.
- legislation.gov.ukSI 2008/410, Schedule 7 paragraph 20B
Which unquoted companies are exempt.
- legislation.gov.ukSI 2008/1911, regulation 12B
SECR for large LLPs.
- legislation.gov.ukCompanies Act 2006, section 414CA
Which companies make climate-related financial disclosures.
- legislation.gov.ukCompanies Act 2006, section 414CB
The eight climate disclosures and the NFSI statement.
- legislation.gov.ukCompanies Act 2006, section 414CZA
The section 172(1) statement.
- Financial Conduct AuthoritySustainability Disclosure Requirements (SDR) regime
Labels, naming and marketing, and the anti-greenwashing rule.
- Financial Conduct AuthorityPS26/19
UK SRS on comply or explain for five listing categories from 2027.
- Financial Conduct AuthorityPS26/19 (PDF)
The reliefs and dates.
- Department for Business and TradeUK Sustainability Reporting Standards
Published 25 February 2026 for voluntary use.
- Department for Business and TradeUK SRS guidance
Who may use them.
- legislation.gov.ukSI 2021/839
Pension scheme climate reporting.
- legislation.gov.ukSI 2025/1349 (ESG Ratings Order)
Providing an ESG rating becomes regulated on 29 June 2028.
- legislation.gov.ukESOS Regulations 2014, Schedule 1
Energy audits for large undertakings.
- legislation.gov.ukModern Slavery Act 2015, section 54
The annual statement.
- legislation.gov.ukSI 2017/172
Gender pay gap reporting.
- Financial Reporting CouncilUK Corporate Governance Code
Comply or explain.
- Department for Business and TradeModernising corporate reporting (consultation)
Proposals; closes 30 November 2026.
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