Careers · role guides · checked 1 October 2026
ESG manager: the desk the questions come to
An ESG manager is the person a UK company sends every question about its environmental, social and governance record to: the regulator’s, the investor’s, the rating agency’s and the customer’s.
From 2027 the questions get sharper, because the FCA’s final rules in PS26/19 bring UK SRS reporting, on a comply-or-explain basis, to listed companies.
This page maps the duties that land on the role to the rule behind each one, then sets out how the title differs from its neighbours, what is really known about pay, and how people get there.
The role
Three kinds of question, one desk
The first kind of question is the regulated one: what the annual report must say about energy, emissions and climate risk.
For a quoted company or a large unquoted one, that starts with streamlined energy and carbon reporting: the energy and emissions figures in the directors’ report.
For the largest companies it adds the eight climate limbs of Companies Act section 414CB(2A), and for listed companies from 2027 it adds UK SRS.
The second kind is requested rather than required: CDP questionnaires, investor surveys, rating-provider reviews and customers asking for supplier data.
None of these has the force of law, but each is read by someone who allocates capital or awards contracts.
The third kind arises only in a financial firm: whether the firm’s own descriptions of its products’ sustainability survive the FCA’s anti-greenwashing rule.
What unites the three is that every answer has to agree with every other one, and with the financial statements.
UK SRS S1 makes that explicit: its ¶23 asks for data and assumptions consistent, as far as possible, with those used in the related financial statements.
That is the main reason the role has moved closer to finance, and why ESG data management is now half the job.
Which duties sit here
Map the duties to your employer
Tick what is true of the company.
The panel lists each duty that follows, what the rule asks, what usually lands on an ESG manager’s desk, and who the law says approves or signs.
No two ESG manager jobs carry the same set of duties, because the duties follow the employer, not the title.
A listed commercial company in the Governance Code’s scope may carry five of them at once: UK SRS, the Companies Act climate disclosures, SECR, ESOS and the board’s Provision 29 declaration.
A private group may carry SECR and ESOS only, with CDP and customer questionnaires on top.
An asset manager carries a different set again: its entity-level TCFD report, the anti-greenwashing rule and, since 25 September 2026, the duty in ESG 2.3.5AR to supply Scope 1, 2 and 3 data to clients who need it for their own disclosures.
In every case the role prepares and someone else signs.
The board approves the strategic and directors’ reports, and ESOS is signed by responsible officers who must be directors or people exercising management control.
That split matters when the ESG manager is asked to “own” a disclosure: the role can own the work, the evidence and the timetable, but not the legal sign-off.
The sustainability director guide follows the accountability up to the board, and the head of sustainability guide sets the same regimes out as a working calendar.
Which duties sit with this role?
2 duties on this desk:
The rule asks: For accounting periods beginning on or after 1 January 2027, climate disclosures against UK SRS S2 and the wider S1 disclosures, or a statement of what is missing, why, and the steps planned. The annual report also says whether any of it was assured, and by whom and to which standard. Companies in UKLR 6, 16 and 22 also state whether they have published a climate transition plan and where, or why not.
Usually on the ESG manager’s desk: Mapping each UK SRS requirement to a disclosure or an explanation, drafting the explanation statement, and keeping a file of evidence behind every figure.
Approves or signs: The rules sit in the annual financial report the board is responsible for; PS26/19 names no individual preparer.
The rule asks: Global Scope 1 and Scope 2 emissions, the underlying energy use, at least one intensity ratio and a narrative on energy efficiency action, in the directors’ report every year.
Usually on the ESG manager’s desk: Owning the energy and emissions figures and the methodology note, and keeping year-on-year comparisons consistent.
Approves or signs: The board approves the directors’ report and a director or the secretary signs it.
A map of what the rules ask, not legal advice.
The “desk” lines describe common practice, not a legal duty on the role.
Nothing you tick is stored or sent.
What 2027 changes
PS26/19 and the explain statement
The FCA’s final rules adopt comply or explain across UK SRS, so nothing in UK SRS is mandatory for a listed company in the strict sense.
What is mandatory is the statement when a company does not comply in full, and writing it will usually fall to the ESG manager.
For climate, UKLR 6.6.6R(7A) asks for a summary of the UK SRS S2 requirements not met, the reasons, and any steps taken or planned to meet them.
For the wider standard, the (7B) limb works by risk rather than requirement: the company names the sustainability-related risks and opportunities it has identified but not disclosed, and says why.
Two reliefs soften the first years: one year’s non-disclosure of Scope 3 emissions under S2, and two years’ non-disclosure of non-climate matters under S1.
A company using a relief says so and, during the relief period, need explain nothing further.
The annual report also states whether any of the disclosures were assured, and if so by whom, to what level and under which standards.
Companies in the commercial companies, non-equity shares and transition categories also state whether they have published a climate transition plan and where, or why not; that statement does not reach secondary listings or depositary receipts.
The FCA’s guidance on what a good explanation looks like is still a draft, Technical Note 803.1, open for comment until 28 October 2026.
The site’s pages on the FCA’s final rules and on what comply or explain requires go through each limb, and the guide to UK SRS S1 and S2 covers the standards themselves.
- 25 Sep 2026FCA 2026/59 in force
Product-level TCFD metric reports replaced by data on request (ESG 2.3.5AR).
- 30 Sep 2026PS26/19 published
UK SRS on a comply-or-explain basis for listed companies.
- 28 Oct 2026Comments due on draft TN 803.1
The FCA’s proposed technical note on comply or explain, in Primary Market Bulletin 66.
- w/c 30 Nov 2026CDP 2026 scores to disclosers
Late responses are marked “not scored”.
- 1 Jan 2027First UK SRS periods begin
Accounting periods beginning on or after this date.
- 2028First reports under the new rules
The year-one Scope 3 relief may be used, and stated.
- 29 Jun 2028ESG ratings regulation applies
SI 2025/1349, main commencement day.
Ratings and questionnaires
CDP, raters and the requests that are not law
Much of an ESG manager’s year is spent on requests that carry no legal weight but real commercial weight.
CDP is the largest: its 2026 full corporate questionnaire runs to thirteen modules, and a company is scored only on its primary sector.
CDP scores nothing outside the response itself, with one exception: the Science Based Targets initiative’s database of validated targets.
A late response is marked “not scored”, and the 2026 scores go to disclosers in the week of 30 November 2026.
A CDP score has no regulatory status anywhere, and a CDP response is not a UK SRS report, however closely CDP describes its alignment with IFRS S2.
ESG ratings are the other large stream, and today they are private opinions.
The ESG Ratings Order 2025 makes providing an ESG rating a regulated activity, but its main provisions apply only from 29 June 2028.
Until then a company’s recourse over a rating it thinks wrong is the provider’s own process, and the ESG manager is usually the person who uses it.
Our guide to answering ESG questionnaires covers the customer and supplier side of the same work.
The job title: the person who runs a company’s ESG disclosure and data work.
The platform: MSCI ESG Manager is MSCI’s online research and analytics platform for asset managers and owners, used to screen portfolios and download research.
Source: MSCI ESG Manager fact sheet
Titles and classification
ESG manager, sustainability manager, reporting manager
| ESG manager | Sustainability manager | Sustainability reporting manager | |
|---|---|---|---|
| Faces | Investors, raters, customers and the annual report | The business: sites, suppliers, products | The annual report and its auditors |
| Typical outputs | Disclosures, questionnaires, data-request replies, claim reviews | The inventory, the reduction plan, the programme | The reporting timetable, the evidence file, the explain statement |
| Often reports to | The CFO, a head of sustainability or a CSO | A head of sustainability or an operations director | The CFO or a group reporting director |
| Skill it leans on | Reading a standard and writing to it; finance literacy | Carbon accounting and change management | Disclosure mechanics and controls |
The clearest single difference between the three titles is the direction the role faces.
An ESG manager faces outwards, to the people who read what the company says; a sustainability manager faces inwards, to the operations that produce the numbers.
For official statistics none of the three titles exists as such.
The ONS Standard Occupational Classification 2020 puts sustainability officers, environmental consultants and energy managers in unit group 2152, Environment professionals.
Which code a given ESG job receives depends on its duties, so a role built around investment analysis may be coded elsewhere.
That is why the one official pay figure below describes an occupation group and not a job title.
Pay
What is known about ESG manager pay
No official statistic reports pay for ESG managers, because no official statistic reports pay by job title.
The one official figure for the nearest occupation is the Home Office going rate for SOC 2152, £37,200, the ONS median for the whole group on a 37.5-hour week.
It covers every grade from graduate to principal, so it says more about the occupation than about a manager within it.
The professional bodies come closer to the role: IEMA’s 2022 survey of 1,190 UK members found an average of £54,601 for members in sustainability or environmental manager roles.
ISEP’s 2025 report found 64% of respondents had a pay rise in the past year, down from 72% in 2022, and that a large organisation pays on average £15,000 to £20,000 more than a small one.
It also found the gender pay gap had widened to 14.7%, and the same survey’s findings show it wider still at senior management level.
No official source publishes a London figure for these roles.
Salary bands quoted elsewhere for ESG managers without a stated sample are recruitment-market claims, so this page does not repeat them.
The sustainability salary benchmarks page sets every official and professional-body figure out in full, and the salary guide in the recruitment section covers the same ground for hiring managers.
| Evidence | Figure | What it measures |
|---|---|---|
| Home Office going rate, SOC 2152 | £37,200 | ONS median for the whole occupation group |
| IEMA 2022, sustainability or environmental manager | £54,601 | Average of members in that role |
| ISEP 2025, Graduate members | £37,069 | Average at the entry grade |
| ISEP 2025, Fellows | £91,911 | Average at the most senior grade |
| ISEP 2025, gender pay gap | 14.7% | Across respondents, up from 8.75% in 2022 |
Getting there
Two routes in: environment or finance
No qualification is required by law to be an ESG manager.
The environment route usually runs through the Institute of Sustainability and Environmental Professionals, which was IEMA until its change of name, and on to chartered status.
The finance route usually starts from an accountancy or investment qualification; ICAEW and ACCA both publish sustainability reporting resources for their members.
On the investment side, the CFA Institute’s Sustainable Investing Certificate is a 100-question exam with no prerequisites.
The National Careers Service’s corporate responsibility and sustainability practitioner profile lists two apprenticeships, at level 4 and at level 7.
The level 7 sustainability business specialist standard includes a duty to lead on business transparency in corporate reporting, which is the ESG manager’s territory exactly.
A common path, though not a fixed one, runs from analyst to ESG manager to head of ESG or head of sustainability, and on to director or chief sustainability officer.
The early rungs are covered in how to become a sustainability consultant.
On demand, the official picture is mixed: ONS’s green jobs estimate is 652,100 full-time equivalents in 2024, up 27.8% on 2015 but 10,800 fewer than in 2023.
Credentials, and who awards them
ISEP grades — GradISEP to FISEP since 17 July 2025, when IEMA’s post-nominals changed.
Chartered Environmentalist — awarded by the Society for the Environment through licensed bodies.
Sustainable Investing Certificate — CFA Institute; no prerequisites, six months to sit.
Apprenticeships — the level 4 corporate responsibility and sustainability practitioner and the level 7 sustainability business specialist.
Hiring, or being hired
Brief on the perimeter, not the title
A hiring manager gets a better shortlist by describing the regimes than by describing the title.
Run the mapper above for the company, and put the duties it lists in the brief, with their dates.
A candidate who has written an explain statement, answered a CDP questionnaire and survived an auditor’s questions on an emissions figure is a different hire from one who has only done one of the three.
Ask whether the candidate has worked to a controls framework, because Provision 29 now asks boards in its scope to declare on the controls over ESG reporting.
If assurance is planned, ask whether they have prepared for an engagement under the FRC’s voluntary ISSA (UK) 5000, which applies to periods beginning on or after 15 December 2026; the guide to sustainability assurance explains what that involves.
A candidate dealing with an agency should know that, under section 6 of the Employment Agencies Act 1973, an employment agency may not charge a work-seeker for finding them work.
The guide to sustainability recruitment agencies explains how they work and what the law says about them.
For companies with EU exposure, the comparison of CSRD and UK SRS sets out where the two regimes differ, and IFRS S2 is the international standard UK SRS S2 builds on.
The UK SRS S1 reference sets out the general requirements the role will spend most of its time inside.
No UK rule requires sustainability disclosures to be assured.
A listed company states whether it obtained assurance and, if so, the provider, the disclosures covered and the standards used.
Sources: PS26/19 ¶2.45 · ISSA (UK) 5000
Frequently asked
ESG manager, answered
What does an ESG manager do?
An ESG manager prepares and defends what a company says about its environmental, social and governance performance.
In practice that means three streams of work: the disclosures the law asks for in the annual report (SECR, the Companies Act climate disclosures and, for listed companies from 2027, UK SRS on a comply-or-explain basis); the questionnaires and data requests that arrive from investors, customers and rating providers such as CDP; and, in an FCA-authorised firm, checking that sustainability claims meet the anti-greenwashing rule.
What does ESG manager mean?
As a job title, an ESG manager is the person who runs a company’s environmental, social and governance disclosure and data work.
The phrase is also the name of a product: MSCI ESG Manager is MSCI’s online ESG research and analytics platform for asset managers and owners.
A search for the job and a search for the platform return different things.
What does an ESG manager earn in the UK?
No official statistic reports pay by job title or seniority for ESG roles.
The only official figure for the nearest occupation group is the Home Office going rate for SOC 2152, Environment professionals, which names sustainability officers: a £37,200 median across the whole occupation.
The professional bodies’ member surveys sit above it: IEMA’s 2022 survey found members in sustainability or environmental manager roles averaged £54,601, and ISEP’s 2025 report puts its Fellows’ average at £91,911.
What is the average salary for an ESG manager in London?
No official source publishes a London figure for ESG managers.
ONS publishes earnings by region for all employees, not by occupation within London, and the Home Office going rate is a single UK-wide figure.
Figures quoted for London ESG roles without a stated sample are recruitment-market claims, not statistics.
Is an ESG manager the same as a sustainability manager?
The titles overlap and employers use them inconsistently.
As a description of common practice, an ESG manager tends to face outwards, towards disclosures, investors and raters, while a sustainability manager tends to run the programme inside the business: the emissions inventory, supplier engagement and the reduction plan.
Many companies have one person doing both.
What job category is an ESG manager in?
ONS has no occupation code called ESG manager.
The nearest unit group in the Standard Occupational Classification 2020 is 2152, Environment professionals, whose job titles include sustainability officers and environmental consultants.
Which code a particular job is given depends on its duties, so a finance-led ESG role may be coded elsewhere.
What qualifications does an ESG manager need?
None is required by law.
Environment-led routes usually run through ISEP membership grades and Chartered Environmentalist status, awarded by the Society for the Environment.
Finance-led routes often add an accountancy qualification or the CFA Institute’s Sustainable Investing Certificate, which has no prerequisites and gives candidates six months to sit a 100-question exam.
Is ESG still a good career path in 2026?
The rules point one way and the jobs data another.
The FCA’s final rules (PS26/19, 30 September 2026) require listed companies in scope to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, which is new disclosure work.
But ONS estimates UK green jobs fell by 10,800 full-time equivalents between 2023 and 2024, to 652,100, in figures it labels official statistics in development.
Does an ESG manager have to get the disclosures assured?
No UK rule requires sustainability disclosures to be assured.
Under the FCA’s final rules a listed company states whether it obtained third-party assurance and, if it did, names the provider, the disclosures assured and the standards used.
ISSA (UK) 5000, the FRC’s assurance standard, is for voluntary use.
Can a recruitment agency charge me to find an ESG job?
Not in England, Wales and Scotland, except in cases the Secretary of State prescribes.
Section 6 of the Employment Agencies Act 1973 bars an employment agency from charging a work-seeker a fee for finding them work, and a breach is an offence.
Since 7 April 2026 the Fair Work Agency enforces agency regulation in Great Britain.
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.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
Listed companies report against UK SRS on a comply-or-explain basis for periods beginning on or after 1 January 2027.
- Financial Conduct AuthorityPS26/19 (PDF): ¶¶1.2, 2.37, 2.45, 3.6, 3.12, 3.14, 3.20 and Appendix 1 (UKLR 6.6.6R(7A), (7B), (8))
The explain statement, the reliefs, the assurance and transition-plan statements, and which listing categories they reach.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
The standards, published 25 February 2026, voluntary for any UK entity.
- Department for Business and TradeUK SRS S1 (PDF), ¶¶21–23 and 26–27
Connected information, consistency with the financial statements, and the governance disclosures.
- legislation.gov.ukCompanies Act 2006, section 414CB(2A)
The eight climate-related financial disclosure limbs in the strategic report.
- legislation.gov.ukSI 2008/410 Schedule 7 paragraph 20B
The SECR exemption test for an unquoted company: two or more “not more than” conditions.
- legislation.gov.ukESOS Regulations 2014 (SI 2014/1643), regulation 4
Phase 4: qualification date 31 December 2026, compliance date 5 December 2027.
- Financial Reporting CouncilUK Corporate Governance Code 2024, Provision 29
The board’s declaration on material controls, including narrative and ESG reporting controls, from 1 January 2026.
- Financial Conduct AuthorityFCA Handbook, ESG 4.3.1R (the anti-greenwashing rule)
Sustainability references must be consistent with the product or service and fair, clear and not misleading.
- Financial Conduct AuthorityFCA Handbook, ESG 2.3.5AR (as made by FCA 2026/59)
From 25 September 2026, Scope 1, 2 and 3 data on request from in-scope asset managers and owners.
- legislation.gov.ukThe FSMA 2000 (Regulated Activities) (ESG Ratings) Order 2025, SI 2025/1349, arts 2, 3 and 6
ESG rating providers become regulated from 29 June 2028.
- CDPFull Corporate Scoring Introduction 2026 (V1.2)
Thirteen modules, primary-sector scoring, late responses not scored.
- CDPCDP scores
Scores released to disclosers in the week of 30 November 2026.
- Financial Reporting CouncilISSA (UK) 5000 (PDF)
The sustainability assurance standard, issued for voluntary use, effective for periods beginning on or after 15 December 2026.
- Office for National StatisticsStandard Occupational Classification (SOC) 2020
Unit group 2152, Environment professionals, which names sustainability officers.
- Home OfficeImmigration Rules Appendix Skilled Occupations, Table 1
The going rate for SOC 2152, £37,200, the median of ONS earnings data.
- Institute of Sustainability and Environmental ProfessionalsState of the Sustainability Profession 2025 (PDF)
What the profession works on, grade averages, pay rises and the gender pay gap.
- IEMA (now ISEP)State of the Profession Survey 2022 (PDF)
Members in sustainability or environmental manager roles averaged £54,601.
- Office for National StatisticsEstimates of green jobs, UK: March 2026
652,100 full-time equivalents in 2024, 10,800 fewer than in 2023.
- CFA InstituteSustainable Investing Certificate
The investment-side ESG certificate: no prerequisites, six months to sit the exam.
- MSCIMSCI ESG Manager (fact sheet)
MSCI’s research and analytics platform of the same name, for asset managers and owners.
- legislation.gov.ukEmployment Agencies Act 1973, section 6
An employment agency may not charge a work-seeker for finding them work.