ESG frameworks UK · owner, audience and legal status

ESG frameworks in the UK: which one does which job

ESG frameworks in the UK are not alternatives on a menu: each was built for a different reader, and only a few carry a legal duty.

The centre moved on 30 September 2026, when the FCA’s final rules in PS26/19 put listed companies onto UK SRS, on a comply-or-explain basis, for accounting periods beginning on or after 1 January 2027.

This page registers each framework by owner and status, explains the tests that divide them, and shows where their content actually overlaps.

Match a framework to your purpose See the register

Vocabulary

Frameworks, standards, platforms and ratings are four different things

The market uses “framework” for everything, which is why comparisons so often line up unlike things.

A standard sets requirements specific enough that a report can be said to comply with it, and a regulator can point at one.

A framework sets out principles and a structure: the TCFD’s four recommendations are the best known, and they were written so that other standards could carry them.

A disclosure platform such as CDP runs a questionnaire and scores the answers.

A rating is a third party’s view of how well a company performs, built from what it discloses and what others say about it.

The useful question is therefore not “which framework is best” but “which job does this report have to do, and for whom”.

What ESG means in the first place is on what is ESG, and its three letters one at a time on the ESG pillars.

Which UK instruments make any of these binding is set out on ESG standards.
Kind	Example	What it gives you
Standard	UK SRS, IFRS S2, ESRS, GRI	Specific requirements a report can comply with
Framework or recommendations	TCFD, TNFD	A structure and principles; no compliance claim of its own
Disclosure platform	CDP	A questionnaire and a score
Rating	MSCI, Sustainalytics, EcoVadis	Someone else’s opinion of your performance

The register · 1 October 2026

Ten frameworks, by owner and UK status

Read the last column first.

Only two rows carry a UK legal duty today, and one of them begins with accounting periods from 1 January 2027.

Sources: FCA PS26/19 · DBT · IFRS Foundation · GRI · European Commission · TNFD · UN Global Compact.
Framework	Owner	Written for	Materiality	UK status
UK SRS S1 and S2	Department for Business and Trade	Investors	Financial	Voluntary; comply or explain for five listing categories from 2027
IFRS S1 and S2	ISSB (IFRS Foundation)	Investors	Financial	The global baseline UK SRS was built from; not UK law
SASB Standards	ISSB	Investors	Financial, by industry	Referenced by UK SRS as “may”; voluntary
TCFD recommendations	FSB task force, disbanded 2023	Investors	Climate, financial	The basis of the listing rule until periods from 1 January 2027
GRI Standards	GRI (GSSB)	All stakeholders	The most significant impacts	Voluntary; no UK instrument requires it
CDP questionnaire	CDP	Investors and customers	Climate, forests, water	Voluntary; no regulatory status
ESRS	European Commission, advised by EFRAG	Investors and stakeholders	Double	EU law where the CSRD reaches a group
EU voluntary standard	European Commission	Smaller companies and their customers	Proportionate	Voluntary; its Annex II caps supplier requests from FY2027
TNFD recommendations	TNFD	Investors	Nature-related	Voluntary; technical work closing, ISSB taking it forward
UN Global Compact principles	UN Global Compact	Stakeholders	Principles-based	Voluntary participation

The duties behind the register

UK company law asks for climate disclosures in its own words at section 414CB, and for energy and carbon under SECR.

The government has confirmed UK SRS S2 as a national reporting framework for section 414CB(6), so a company using it need not duplicate those eight disclosures.

The global principle-setters

The UN Global Compact asks participants to commit to ten principles on human rights, labour, environment and anti-corruption.

It is a participation commitment, not a reporting standard, and nothing in UK law refers to it.

Selector

Match a framework to what the report must do

The selector beside this text starts from purpose, because that is the only reliable way to choose.

Tick each job the report has to do, and it returns the framework that does it, the body that owns it and its status in the UK.

A listed company will usually tick three or four boxes, and the answer is a set of frameworks reconciled from one dataset rather than one framework.

Purposes with a legal duty behind them come first, because a voluntary framework never displaces a statutory requirement.

The statutory duties in full, instrument by instrument, are on ESG reporting requirements in the UK, and how a company runs them as one programme on ESG reporting in the UK.

What must the report do? · tick all that apply

Meet the FCA listing rules as a listed companyMeet the Companies Act climate disclosure dutyReport UK energy and carbon in the directors’ reportGive investors decision-useful sustainability informationReport our impacts to a wide set of stakeholdersAnswer a customer’s or investor’s CDP requestReport for an EU subsidiary inside the CSRDAnswer EU customers’ supplier data requests proportionatelyDisclose nature-related risks

SECR, with the Environmental Reporting Guidelines

OWNER Parliament (SI 2008/410 Sch 7); DESNZ guidance

Law since financial years from 1 April 2019 for quoted companies and large unquoted companies and LLPs.

UK SRS (or IFRS S1 and S2), with SASB industry metrics

OWNER DBT; ISSB, which also owns the SASB Standards

Voluntary outside the listing categories.

UK SRS lets an entity “refer to and consider” SASB (“may”), where IFRS S1 says “shall”.

Most groups end up reconciling two or three of these from one dataset.

Where you must choose, the frameworks that carry a legal duty come first.

History

How a crowded field consolidated around the ISSB

The word ESG was set out in December 2004 in Who Cares Wins, a report by twenty financial institutions convened by the UN Global Compact at Kofi Annan’s invitation.

For the next decade and a half, frameworks multiplied faster than anyone could reconcile them.

The consolidation came in three moves.

First, the Value Reporting Foundation consolidated into the IFRS Foundation on 1 August 2022, bringing the SASB Standards under the ISSB.

Second, the ISSB issued IFRS S1 and IFRS S2 in June 2023, carrying the TCFD’s structure into a standard that jurisdictions could adopt.

Third, the FSB disbanded the TCFD on 12 October 2023 and asked the ISSB to monitor progress on climate disclosure; the IFRS Foundation’s TCFD page records the handover.

The UK then adopted the ISSB standards as UK SRS, published by the Department for Business and Trade on 25 February 2026, with the differences mapped in Annex A of the government response, which gives no count of them.

The EU went its own way with the ESRS, and the investor-focused and impact-focused traditions still run side by side.

The world’s standard-setters are mapped on the global standards landscape, and a framework-by-framework editorial reading sits on our sister reference, sustainabilityreportingstandards.co.uk.

Dec 2004
Who Cares Wins
Twenty financial institutions set out the ESG case, convened by the UN Global Compact.
Jun 2017
TCFD Final Report
Four recommendations, eleven recommended disclosures.
1 Aug 2022
VRF joins the IFRS Foundation
The ISSB takes on the SASB Standards.
Jun 2023
IFRS S1 and S2 issued
12 Oct 2023
TCFD disbanded
The FSB asks the ISSB to monitor progress.
25 Feb 2026
UK SRS S1 and S2 published
For voluntary use, by DBT.
21 Sep 2026
Revised ESRS published
DR (EU) 2026/1563, applying from FY2027.
30 Sep 2026
FCA PS26/19
UK SRS on comply or explain for listed companies.
1 Jan 2027
Listing rules apply; GRI 102 effective

The dividing line

Two tests of what matters, and a third that combines them

Most confusion between frameworks comes from the question each one asks about what to include.

UK SRS S1 asks for sustainability-related risks and opportunities that could reasonably be expected to affect the entity’s cash flows, its access to finance or its cost of capital, and treats information as material if it could influence the decisions of the primary users of financial reports.

GRI asks something else: its material topics are the organisation’s most significant impacts on the economy, environment and people, including on human rights.

The two boards put it plainly in their joint statement of 26 May 2026: GRI serves “a range of stakeholders, including investors” with information about impacts, and the ISSB serves investors with information about risks and opportunities.

The EU’s ESRS combine the two lenses, and GRI itself says “The European Union dubbed this concept ‘Double Materiality’”, describing its own standards as the impact side.

A UK-only reporter therefore runs one test for UK SRS and, if it also reports to GRI, a second; a group reached by the CSRD runs the combined one.

The combined test is worked through on double materiality, and the regime comparison on CSRD vs UK SRS.

Sources: UK SRS S1 ¶¶3, 17–18 · GRI 1 §2.2 · European Commission
Test	Question it asks	Used by
Financial	Could the information reasonably be expected to influence investors’ decisions, judged through cash flows, access to finance or cost of capital?	UK SRS, IFRS S1 and S2, SASB
Impact	What are the organisation’s most significant impacts on the economy, environment and people?	GRI
Double	Both, as two lenses on one assessment	ESRS under the CSRD

Interoperability

What GRI and the ISSB have actually agreed

“GRI and the ISSB are interoperable” is said often, and the published record is narrower.

It consists of a memorandum of understanding in 2022, a joint statement on interoperability in May 2024, a statement on greenhouse gas equivalence in June 2025 and a joint statement in May 2026.

The May 2026 statement says the ISSB and the GSSB “make decisions separately in accordance with their established standard-setting due processes”.

The one operative mechanism is emissions: under the GRI 102 and IFRS S2 equivalence statement, a company reporting under both can use its IFRS S2 Scope 1, 2 and 3 disclosures to meet the corresponding GRI 102 requirements.

That works only where emissions are measured on the GHG Protocol Corporate Standard, with a cross-reference in the GRI content index.

It bites from 1 January 2027, when GRI 102: Climate Change 2025 takes effect and replaces GRI 305’s emissions disclosures.

No disclosure-level correspondence table between the two sets of standards had been published as at September 2026, and the boards’ own list of current joint work does not include one.

The GRI numbering itself is a trap: since 2024, GRI 101, 102 and 103 mean Biodiversity, Climate Change and Energy, not the 2016 Foundation, General Disclosures and Management Approach, which is set out on GRI Standards.

SASB in the UK

SASB: owned by the ISSB, and softer in the UK

The IFRS Foundation’s own words are that the ISSB “is responsible for the SASB Standards” and is maintaining and enhancing them.

The standards cover 77 industries across 11 sectors, classified by SASB’s Sustainable Industry Classification System.

IFRS S1 requires an entity to refer to and consider the SASB disclosure topics; UK SRS made that permissive, and the government said it would review the change once the ISSB’s SASB enhancement project concludes.

A company claiming IFRS S1 compliance is therefore in a different position from one claiming UK SRS S1 compliance.

SASB still matters in practice, because industry-based metrics are what investors compare across peers, and UK SRS S2 still asks for them.

The ownership chain and the exact paragraphs are on SASB Standards.

Where UK SRS differs from IFRS on SASB

UK SRS S1 ¶¶55(a) and 58(a): an entity “may refer to and consider” the SASB Standards, where IFRS S1 says “shall”.

UK SRS S2 ¶¶12 and 32: “may”; ¶23 uses “shall” for cross-industry metrics and “may” for industry-based ones; ¶37 kept “shall”.

UK SRS S1 ¶59(a): you must still say which SASB topics you applied.

Sources: UK SRS S1 · UK SRS S2

Lineage

From the TCFD to the UK listing rules

The TCFD’s Final Report of June 2017 set four recommendations, on governance, strategy, risk management, and metrics and targets, with eleven recommended disclosures beneath them.

Four recommendations and eleven disclosures are two layers, and are often confused.

IFRS S2 carried that structure into a standard and added industry-based metrics, information on planned carbon credits and financed emissions.

UK SRS S2 is the UK version of IFRS S2 as amended by the ISSB in December 2025.

The FCA’s TCFD-aligned listing rule has applied to listed companies since 2021, and PS26/19 ¶1.10 says the new rules “will replace the existing TCFD aligned disclosures”.

For accounting periods beginning on or after 1 January 2027, a company in UKLR 6, 14, 15, 16 or 22 reports against UK SRS S2, or summarises what it has not met, why, and the steps it plans.

CP26/5 had proposed making S2 mandatory; the final rules put all of UK SRS on comply or explain.

The recommendations themselves are on TCFD and the TCFD framework, and the paragraph-level standards on UK SRS S1 and S2.

Beyond the UK core

ESRS, the voluntary standard and nature

The ESRS are EU law for groups the CSRD reaches, and after Omnibus I that means undertakings exceeding both 1,000 employees and €450 million net turnover, for financial years from 2027.

The revised standards were published as Delegated Regulation (EU) 2026/1563, applying to financial years beginning on or after 1 January 2027, with EFRAG as the Commission’s technical adviser.

Alongside them, the Commission adopted a voluntary standard for smaller companies, whose Annex II also caps what a CSRD reporter may require from a supplier averaging 1,000 employees or fewer.

That cap is the framework a UK supplier is most likely to meet without knowing its name, and it is worked through on the ESG questionnaire page.

On nature, the TNFD’s recommendations remain voluntary, and the taskforce said it would complete its technical work by the third quarter of 2026 as the ISSB takes nature-related standard-setting forward.

The FRC’s sustainability FAQs say any new ISSB standard, on nature or human capital for example, would need its own UK endorsement before it became part of UK SRS.

Finding reports

How to find any company’s sustainability reporting

A company’s ESG reporting usually sits in three places at once, and each holds a different part.

The annual report carries what the law requires: SECR in the directors’ report, the climate disclosures in the strategic report, and for listed companies the listing-rule statement.

For a company on a UK market, the FCA’s National Storage Mechanism stores annual financial reports as regulated information, so the filed version can be found even if the website moves.

For any UK company, Companies House holds the filed accounts, which is how SECR disclosures by private companies can be read.

A separate sustainability or impact report, often GRI-based, is usually on the company’s own site, with a GRI content index at the back if it claims GRI reporting.

A CDP response is public only if the company has chosen to make it so.

Worked examples of published UK reports, read section by section, are on ESG reporting examples.

Software that handles several frameworks from one dataset is compared on the site’s software pages, and the criteria investors apply on ESG criteria.

Where	What you find	For whom
The company’s investor or sustainability pages	Annual report, sustainability report, GRI index, CDP response	Any company that publishes them
FCA National Storage Mechanism	Annual financial reports filed as regulated information	Issuers on UK markets
Companies House	Filed accounts, including the strategic and directors’ reports	Every UK company
CDP	Responses a company has chosen to make public	CDP disclosers

Test yourself

Eight statements, true or false

The statements beside this text are the claims most often made about these frameworks, and each answer names its source.

Three of them are among the commonest errors in published comparisons: that S2 became mandatory, that UK SRS requires SASB, and that GRI is a double materiality standard.

The first was the consultation’s proposal and not the final rule.

The second was true of IFRS S1 but was softened in the UK text.

The third mixes up GRI’s impact test with the EU’s combined one.

How ESG reporting differs from the older corporate responsibility tradition is on ESG vs CSR.

ESG frameworks · true or false

GRI asks an organisation to report its most significant impacts on the economy, environment and people.
SASB Standards are now the responsibility of the ISSB.
The TCFD still issues guidance and status reports.
CDP assures a company’s financial statements.
Under the FCA’s final rules, UK SRS S2 is mandatory for listed companies from 2027.
UK SRS requires a company to apply the SASB Standards.
The EU’s ESRS apply double materiality.
GRI describes its own standards as double materiality standards.

0 of 8 answered.

Nothing you choose is stored or sent.

Frequently asked

ESG frameworks, answered

What are ESG frameworks?

ESG frameworks are published sets of principles, standards or questionnaires that tell a company what environmental, social and governance information to report and how.

In the UK the main ones are UK SRS S1 and S2 (built on the ISSB’s IFRS S1 and S2), the GRI Standards, the SASB Standards, the TCFD recommendations, CDP’s questionnaire, the EU’s ESRS and the TNFD recommendations.

They serve different audiences and only some carry a legal duty.

Which ESG framework should a UK company use?

Start with the one the law points you to.

A listed company in UKLR 6, 14, 15, 16 or 22 reports against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027 under FCA PS26/19.

Large companies with more than 500 employees in the s.414CA categories report eight climate disclosures under the Companies Act.

Beyond that, investors look to UK SRS or IFRS with SASB metrics, and wider stakeholders to GRI.

What is the difference between GRI, SASB and TCFD?

GRI reports an organisation’s most significant impacts on the economy, environment and people, for a wide set of stakeholders.

SASB gives industry-specific metrics for investors, across 77 industries, and is now owned by the ISSB.

The TCFD gave four climate recommendations and eleven recommended disclosures for investors; it disbanded on 12 October 2023 and its content was carried into IFRS S2 and UK SRS S2.

Is SASB still relevant after the ISSB took over?

Yes.

The ISSB is responsible for the SASB Standards and is maintaining and enhancing them.

IFRS S1 requires an entity to refer to and consider them.

UK SRS S1 softens that to “may refer to and consider” at paragraphs 55(a) and 58(a), with the same change in UK SRS S2 at paragraphs 12, 23 and 32, but paragraph 59(a) still requires an entity to disclose which SASB topics it did apply.

What replaced the TCFD in the UK?

UK SRS S2, through the FCA’s listing rules.

PS26/19 says the new rules “will replace the existing TCFD aligned disclosures”, for accounting periods beginning on or after 1 January 2027, on a comply-or-explain basis.

The TCFD itself disbanded on 12 October 2023, and the FSB asked the ISSB to monitor climate disclosure from 2024.

Are GRI and the ISSB standards interoperable?

Partly.

The two have a 2022 memorandum of understanding, a 2024 joint statement on interoperability and a 26 May 2026 joint statement saying the boards make decisions separately.

The one operative mechanism is GHG emissions: a company reporting under both GRI 102 and IFRS S2 can use its IFRS S2 Scope 1, 2 and 3 disclosures to meet GRI 102, measured on the GHG Protocol Corporate Standard.

GRI 102 takes effect on 1 January 2027.

Does GRI use double materiality?

Not in its own terms.

GRI reports impacts: its material topics are an organisation’s most significant impacts on the economy, environment and people.

GRI says the European Union named the combined approach “double materiality” and that its standards represent the impact side of it.

The EU’s ESRS apply double materiality; UK SRS applies financial materiality.

How do I find a company’s sustainability report?

Start with the company’s own investor or sustainability web pages, where the annual report and any separate sustainability report sit.

For a UK-listed company, the FCA’s National Storage Mechanism holds annual financial reports filed as regulated information.

For any UK company, Companies House holds its filed accounts, and the strategic and directors’ reports inside them carry the climate and SECR disclosures where they apply.

Many companies also publish their CDP responses.

Is any ESG framework mandatory in the UK?

No framework is mandatory as such.

UK law requires particular disclosures, such as SECR and the Companies Act climate disclosures, and the FCA requires listed companies in five categories to report against UK SRS or explain.

GRI, SASB, CDP and TNFD are voluntary in the UK, and the ESRS bind only where the EU’s CSRD reaches a group.

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.

Checked against 31 sources fromDepartment for Business and TradeFinancial Conduct Authoritylegislation.gov.ukIFRS FoundationFinancial Stability BoardTCFD

Department for Business and Trade
UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026 for voluntary use.
Department for Business and Trade
UK SRS S1 (PDF), ¶¶3, 17–18, 55(a), 58(a), 59(a)
Financial materiality, and SASB softened from “shall” to “may”.
Department for Business and Trade
UK SRS S2 (PDF), ¶¶12, 23, 32, 37
Where the SASB reference is “may” and where it stayed “shall”.
Department for Business and Trade
Government response on UK SRS
Annex A maps the differences from IFRS; UK SRS S2 as a national framework for s.414CB(6).
Financial Conduct Authority
PS26/19: Aligning listed issuers’ sustainability disclosures with international standards
Final rules: UK SRS on comply or explain for five listing categories, periods from 1 January 2027.
Financial Conduct Authority
PS26/19 (PDF), ¶¶1.2, 1.7, 1.10, 3.6, 3.12
The basis, the scope, the start date and the replacement of the TCFD-aligned disclosures.
Financial Conduct Authority
CP26/5 — the consultation PS26/19 finalises
The proposals the final rules changed.
legislation.gov.uk
Companies Act 2006, section 414CB
The eight climate disclosures in the strategic report.
IFRS Foundation
International Sustainability Standards Board
The board that issued IFRS S1 and S2 in June 2023.
IFRS Foundation
IFRS S1 General Requirements
The global baseline UK SRS S1 is built on.
IFRS Foundation
IFRS S2 Climate-related Disclosures
The global baseline UK SRS S2 is built on.
IFRS Foundation
IFRS Foundation completes consolidation with Value Reporting Foundation (1 August 2022)
The ISSB “now governs the SASB Standards”.
IFRS Foundation
SASB Standards
“The ISSB is responsible for the SASB Standards.”
IFRS Foundation
SICS industry list (10 October 2025)
77 industries across 11 sectors.
IFRS Foundation
IFRS Foundation and the TCFD
Monitoring of climate disclosure after the TCFD disbanded.
Financial Stability Board
Task Force on Climate-related Financial Disclosures
The task force the FSB created and disbanded on 12 October 2023.
TCFD
Final Report: Recommendations of the TCFD (June 2017)
Four recommendations and eleven recommended disclosures.
Global Reporting Initiative
GRI Standards
Universal, Sector and Topic Standards; GRI 102 and 103 effective 1 January 2027.
Global Reporting Initiative
GRI 1: Foundation 2021
Material topics as the most significant impacts on the economy, environment and people.
GRI and IFRS Foundation
Joint statement (26 May 2026)
The two boards “make decisions separately”; the purpose of each set of standards.
GRI and IFRS Foundation
GRI 102 and IFRS S2: statement on equivalence for GHG emissions (26 June 2025)
The one operative interoperability mechanism, for Scope 1, 2 and 3.
Global Reporting Initiative
GRI policy paper on double materiality
“The European Union dubbed this concept ‘Double Materiality.’”
European Commission
Corporate sustainability reporting
The CSRD and the ESRS.
EUR-Lex
Delegated Regulation (EU) 2026/1563 (revised ESRS)
Applies to financial years beginning on or after 1 January 2027.
EUR-Lex
Directive (EU) 2026/470 (Omnibus I)
CSRD scope: both 1,000 employees and €450 million net turnover.
EUR-Lex
Delegated Regulation (EU) 2026/1560 (the voluntary standard)
The standard whose Annex II caps supplier requests.
TNFD
ISSB decision on nature-related standard-setting (November 2025)
The TNFD completes its technical work by Q3 2026.
IFRS Foundation
ISSB agrees proposed way forward on nature-related disclosures (May 2026)
The ISSB’s nature project.
Financial Reporting Council
Sustainability reporting developments: FAQs
The FRC’s account of the UK framework and its standards.
Financial Conduct Authority
National Storage Mechanism
Where listed issuers’ annual financial reports are stored.
Greenhouse Gas Protocol
Corporate Accounting and Reporting Standard
The measurement basis UK SRS S2, GRI 102 and SECR practice share.