ESG frameworks — UK comparison — 2026 guide
Eight major ESG frameworks compared for UK preparers in 2026. UK SRS is the emerging mandatory baseline, IFRS S1/S2 is the global standard it inherits from, TCFD was disbanded in October 2023, GRI remains the impact-focused alternative, SASB brings industry-specific depth, CDP drives the climate questionnaire market, and ESRS/CSRD matters for EU subsidiaries.
Why so many frameworks?
Each framework emerged for a different audience and purpose. The consolidation toward UK SRS / IFRS doesn’t eliminate the others — it changes how UK companies map across them.
What each framework is
Glossary covering the eight frameworks every UK preparer encounters: origin, audience, materiality lens and UK relevance.
- UK SRSUK · Voluntary today; mandatory S2 proposed
- UK Sustainability Reporting Standards — investor-focused standards issued by the Secretary of State for Business and Trade, endorsing IFRS S1 and S2. Annex A of the government response maps how they differ and carries no count.3 CP26/5 proposes it as the mandatory baseline for the 515 listed companies in UKLR 6, 16 and 22, with 89 more in UKLR 14 and 15 owing only a statement about their primary listing venue, for accounting periods beginning on or after 1 January 2027.8
- IFRS S1 + S2Global · Adopted by jurisdictions
- ISSB-issued global investor-focused sustainability standards (June 2023).1 IFRS S1: general requirements; IFRS S2: climate-specific. Adopted in UK as UK SRS; in Australia as ASRS; in Japan as JSSB. Foundation for global comparability.
- TCFDDisbanded · Absorbed
- Task Force on Climate-related Financial Disclosures— established by the FSB in December 2015, Final Report June 2017: four recommendations and, beneath them, eleven recommended disclosures — not eleven recommendations. Disbanded 12 October 2023. IFRS S2 is consistent with all four and all eleven, and adds industry-based metrics, planned use of carbon credits and financed emissions on top. Still live in the UK through UKLR 6.6.6R(8); CP26/5 proposes deleting those rules, and no Policy Statement has been made.
- GRIVoluntary · Impact-focused
- Global Reporting Initiative — leading voluntary framework for multi-stakeholder sustainability reporting. Its test is the significance of the organisation’s own impacts on the economy, environment and people (GRI 1 §2.2); GRI does not use the term “impact materiality”.5 Strong on social and biodiversity topics. Used by many UK companies for standalone sustainability reports alongside UK SRS for annual-report ESG disclosure — see GRI's Universal Standards and the 101/102/103 numbering trap for the full breakdown.
- SASB StandardsIndustry-specific · IFRS-owned
- Sustainability Accounting Standards Board industry standards covering 77 industries.7 Now part of IFRS Foundation. Referenced by IFRS S1 (and therefore UK SRS S1, on optional basis under the UK amendment). The leading source of industry-specific KPIs — see who the ISSB says is actually responsible for them now for the ownership chain and exactly which UK SRS paragraphs stayed a “shall”.
- CDPQuestionnaire · Voluntary
- CDP (formerly Carbon Disclosure Project) — annual questionnaire on climate, water and forests.6 CDP reports that over 23,100 organisations disclosed through it in 2025 — 22,100 of them companies, plus over 1,000 cities, states and regions. Scoring runs A to D-, in four levels (Disclosure, Awareness, Management, Leadership), and drives investor and supply-chain perception. Aligning with TCFD/IFRS S2 disclosures supports CDP A-list scoring.
- ESRS / CSRDEU · Mandatory
- European Sustainability Reporting Standards under the EU Corporate Sustainability Reporting Directive. After Omnibus I (Directive (EU) 2026/470), mandatory only where an undertaking exceeds both 1,000 employees and €450m net turnover, for financial years beginning on or after 1 January 2027. Uses double materiality. UK companies with EU subsidiaries face ESRS exposure. See CSRD vs UK SRS.
- UN Global CompactVoluntary · CSR-tinged
- Voluntary corporate citizenship initiative with 10 principles across human rights, labour, environment and anti-corruption. Annual Communication on Progress (CoP) required. Less investor-focused than UK SRS / IFRS but valuable for stakeholder narratives.
Eight frameworks across nine dimensions
Audience, materiality, mandatory status, UK relevance, scope, level of detail, industry specificity, assurance compatibility and ISSB alignment.
Why UK SRS is becoming the centre of gravity
Five reasons UK preparers should organise around UK SRS even before mandatory application: investor demand, framework convergence, FCA regulation, supply chain pressure, and assurance readiness.
FCA CP26/5, published on 30 January 2026, proposes mandatory UK SRS S2 for companies listed in UKLR 6, 16 and 22 — not for all five categories it names — for accounting periods beginning on or after 1 January 20278, and proposes deleting the current TCFD-aligned climate disclosure rules. It does not delete UKLR 6.6.6R(8) outright: limbs (a) and (b) go, limb (c) survives amended, and (d) and (e) become new assurance and transition-plan statements, with UK SRS carried by new 6.6.6R(7A)–(7C).
The FRC published ISSA (UK) 5000 on 12 November 2025, for voluntary use by UK assurance providers. It is effective for engagements on sustainability information reported for periods beginning on or after 15 December 2026, or as at a specific date on or after that day, and earlier application is permitted. No UK entity is under any legal duty to obtain sustainability assurance, and CP26/5 ¶7.5 says the FCA is “not proposing to set mandatory requirements for the assurance of sustainability reporting at this time”.9
Why UK SRS will dominate UK ESG reporting
(1) FCA CP26/5 proposes mandatory UK SRS S2 for the 515 listed companies in UKLR 6, 16 and 22, with 89 more in UKLR 14 and 15 on a lighter statement branch, for accounting periods beginning on or after 1 January 2027 — proposed, with no Policy Statement as at August 2026.
(2) Investor demand.
(3) Framework convergence: the TCFD disbanded in 2023 and IFRS S2 is consistent with its four recommendations and eleven recommended disclosures, SASB is referenced (permissively in the UK), GRI is mapped.
(4) Supply chain pressure: large customers cascading UK SRS expectations to suppliers.
(5) Assurance readiness: ISSA (UK) 5000, published November 2025 for voluntary use, is built for these disclosures — though no UK entity is obliged to obtain assurance.
ESG frameworks — frequently asked
Which to use, multiple frameworks, UK SRS vs GRI, SASB status, and what replaced TCFD.
Which ESG framework should UK companies use?
UK SRS (built on IFRS S1 and S2) is the sensible starting point for any UK preparer, though nobody is required to use it today — the standards were published on 25 February 2026 for voluntary use by any entity that chooses to apply them.
UK SRS is investor-focused and applies single, financial materiality: whether information could reasonably be expected to influence the decisions of primary users of general purpose financial reports, judged by reference to the entity's cash flows, access to finance or cost of capital.
The FCA has proposed mandatory UK SRS S2 for the 515 listed companies in UKLR 6, 16 and 22, with a further 89 in UKLR 14 and 15 on a lighter statement branch, for accounting periods beginning on or after 1 January 2027 — a consultation that closed on 20 March 2026 and has produced no Policy Statement.
Most large UK companies will align anyway, because investors and supply-chain customers ask for it.
Do I need to report under multiple ESG frameworks?
Often yes, but the data set is largely common.
A UK listed company with EU operations might face: UK SRS S1+S2 (voluntary today; mandatory UK SRS S2 proposed for accounting periods beginning on or after 1 January 2027), SECR (currently mandatory), TCFD-aligned Listing Rules (currently mandatory), EU CSRD/ESRS (if EU subsidiary thresholds met), plus voluntary disclosures to investors via GRI (impact) and CDP (climate scoring).
The practical task is collecting data once and mapping across frameworks.
What is the difference between UK SRS and GRI?
UK SRS applies single, financial materiality — whether information could reasonably be expected to influence the decisions of primary users of general purpose financial reports (UK SRS S1 paragraph 18), by reference to the entity's cash flows, access to finance or cost of capital (paragraph 3).
Note that the phrase 'enterprise value' appears nowhere in either Standard.
GRI's own test is different again, and the phrase 'impact materiality' appears nowhere in the GRI Standards themselves, although GRI uses it in its commentary outside them.
GRI 1: Foundation 2021 asks an organisation to prioritise its most significant impacts on the economy, environment and people, including impacts on their human rights, and calls those its material topics.
Both can coexist: many UK companies use UK SRS for the annual report and GRI for the broader sustainability report addressing wider stakeholders.
Is SASB still relevant after the ISSB took over?
Yes.
SASB Standards are now owned by the IFRS Foundation alongside IFRS S1/S2 and remain the leading industry-specific sustainability disclosure standards.
IFRS S1 and S2 explicitly require companies to consider SASB-based industry-specific disclosures.
UK SRS keeps the SASB reference but softens it: UK SRS S1 paragraphs 55(a) and 58(a) read 'may refer to and consider' where IFRS S1 reads 'shall', and the same change lands at UK SRS S2 paragraphs 12, 23 and 32.
It is not fully optional, though — paragraph 59 still says an entity 'shall' identify the sources of guidance it has applied, including any SASB disclosure topics it used.
Do not describe the UK's differences from IFRS by a count: six was the number of amendments the government proposed in June 2025, and Annex A of the consultation response, which maps the final differences, carries no total.
What replaced TCFD?
IFRS S2 Climate-related Disclosures (issued by the ISSB in June 2023) carries the TCFD's four recommendations and eleven recommended disclosures — the IFRS Foundation's own word is 'consistent with' — and then asks for more: industry-based metrics, information about planned use of carbon credits, and additional information about financed emissions.
Note the two nested layers: four recommendations, eleven recommended disclosures beneath them.
The TCFD was disbanded on 12 October 2023, and monitoring of climate-related disclosure adoption transferred from 2024.
UK SRS S2 is the UK-endorsed version of IFRS S2 as amended by the ISSB in December 2025; the government's own difference map, Annex A of the consultation response, carries no count of UK amendments, so do not quote one.
The FCA's CP26/5 proposes replacing the TCFD-aligned UK Listing Rules with mandatory UK SRS S2 for accounting periods beginning on or after 1 January 2027, but that remains a proposal.
The ESG guide set
From frameworks, continue to standards, criteria, practical reporting, software and strategy.
What is ESG?
Definition, history, three pillars, UK frameworks.
ArchitectureThe three ESG pillars
Environmental, Social, Governance — what each covers.
CompareESG vs CSR
Five differences between ESG and CSR.
StandardsESG standards — UK regulatory landscape
UK SRS, FCA SDR, SECR, SI 2022/31 — the standards-based regime.
CriteriaESG criteria
Practical criteria per pillar.
HubESG reporting — UK hub
Three-layer UK system; UK SRS backbone.
Related guides & references
Global sustainability standards landscape
Comprehensive view of the global sustainability standards landscape.
CSRD vs UK SRS
How EU CSRD and UK SRS differ on materiality, scope and timing.
TCFD framework — four recommendations, eleven recommended disclosures
The climate-specific framework UK SRS S2 is built on.
Primary references
IFRS Foundation, DBT, FCA, GRI, CDP and standards bodies cited throughout this page.