ESG reporting · UK practice, with the law behind it
ESG reporting in the UK: what it is and how it works
ESG reporting in the UK is the disclosure of environmental, social and governance information, spread across several duties and voluntary frameworks rather than gathered into one report.
The centre of gravity moved today: the FCA’s PS26/19 requires listed companies in five categories to report against UK SRS, or explain, for accounting periods beginning on or after 1 January 2027.
This page explains the layers of UK ESG regulation, who reports, who asks for data and on what authority, and turns the duties that apply to you into a plan.
Definition
What ESG reporting means in UK practice
ESG stands for environmental, social and governance, and ESG reporting is the practice of disclosing information under those three headings.
The phrase is the market’s, not Parliament’s: the UK instruments are called UK Sustainability Reporting Standards, Sustainability Disclosure Requirements and Streamlined Energy and Carbon Reporting.
Most UK ESG reporting happens inside the annual report and accounts, not in a stand-alone document.
Energy and carbon go in the directors’ report under Schedule 7 to SI 2008/410.
Climate risk goes in the strategic report under the Companies Act, as amended by SI 2022/31.
For listed companies, UK SRS disclosures will sit in the annual financial report under UKLR 6.6 as the FCA has now amended it.
Many large groups also publish a separate sustainability report, usually against voluntary frameworks, and that is a choice rather than a duty.
The meaning of ESG itself, and its history, is on what is ESG; the three letters one at a time are on the ESG pillars.
In the FCA’s naming and marketing rules, which restrict “ESG” and twelve other terms in the names and promotions of retail investment products.
It is a limit on fund marketing, not a reporting duty for companies.
Source: FCA Handbook ESG 4.3.2R
Structure
Four layers of UK ESG regulation, four different targets
People who say “ESG regulation” usually mean one of four things.
They regulate different people, and confusing them produces most of the bad advice on the subject.
1 · Company disclosure
What companies must publish about themselves: SECR, climate-related financial disclosure, UK SRS for listed companies, modern slavery statements and gender pay gap figures.
The FCA’s PS26/19 is the newest part of this layer, and the full list is on ESG reporting requirements in the UK.
2 · Investment products
How funds may be labelled and described: the FCA’s SDR regime and its four sustainability labels.
The anti-greenwashing rule, ESG 4.3.1R, reaches every authorised firm’s sustainability claims to UK clients.
3 · The ratings market
The firms that turn ESG data into scores: the ESG Ratings Order 2025, made on 15 December 2025.
Providers need FCA authorisation from 29 June 2028; the rated companies gain no new duty.
4 · Requests down the value chain
What customers, investors and lenders ask suppliers for, which is governed mostly by contract.
The exception is the EU’s value chain cap in Omnibus I, covered on the ESG questionnaire page.
The FCA’s own overview of its part is its climate change and sustainable finance page.
Populations
Who reports on ESG in the UK today
SECR is the widest regime by population: DESNZ measured about 19,900 quoted companies, large unquoted companies and large LLPs in its scope.
It catches a quoted company at any size, and an unquoted company or LLP that does not meet two of the “not more than” conditions of £36 million turnover, £18 million balance sheet and 250 employees.
The FCA’s UK SRS rules reach companies listed in UKLR 6, 14, 15, 16 and 22, whatever their size.
PS26/19 publishes no count; its consultation estimated around 600 affected companies, and PS26/19 notes that 89 secondary-listing and depositary-receipt issuers now face the same requirements as domestic issuers.
ESOS reaches undertakings with at least 250 employees, or with both turnover over £44 million and a balance sheet over £38 million, and its Phase 4 test is taken on 31 December 2026 (Environment Agency); the scheme is explained in the ESOS guide.
A UK group can also be reached by the EU’s CSRD through an in-scope EU subsidiary, and the two regimes are compared on CSRD vs UK SRS.
Overlap is normal: a company over SECR’s headcount limb is often over ESOS’s too, and most companies in the FCA’s categories also report under SECR.
Everyone else, including most SMEs, has no ESG reporting duty at all, and meets ESG through customer requests instead.
Planner
Turn the duties that apply into a plan
Tick the duties that reach your company, and the planner orders the work: what to collect, which document each disclosure lives in, who signs it and when it is due.
If you do not yet know which duties apply, the checker on ESG reporting requirements in the UK runs your figures through each test.
The order starts with site-level energy data because three duties draw on it: ESOS measures it, SECR reports it and climate disclosure analyses it.
The governance evidence comes next, because board minutes on climate oversight serve the strategic report, UK SRS governance disclosures and, for companies under the Code, the Provision 29 declaration.
UK SRS then adds what the older duties never asked for: Scope 3 after the one-year relief, and sustainability risks beyond climate after the two-year relief (PS26/19 ¶3.14).
Nothing you tick leaves your browser; the privacy policy and terms of service cover every tool on the site.
The practical side of holding the data is on ESG data management, and the tools on ESG software compared and carbon reporting software.
Your reporting plan · tick what applies
- Step 1: ESOSCOLLECT Total energy consumption across buildings, transport and processes, and an asset register to show the 95% coverage.WHERE An ESOS assessment, notified to the Environment Agency; action plan published by the administrator.SIGN-OFF Director-level responsible officers, with a lead assessor’s review unless exempt.WHEN Notify by 5 December 2027; action plan by 5 December 2028.
- Step 2: SECRCOLLECT kWh from gas, transport fuel and electricity; Scope 1 and 2 on the government conversion factors; an intensity ratio; last year’s figures.WHERE Directors’ report (companies) or energy and carbon report (LLPs).SIGN-OFF The board approves the directors’ report; for an LLP, the members, signed by a designated member.WHEN With the annual report and accounts, every financial year.
- Step 3: Section 172(1) statementCOLLECT How the board weighed employees, suppliers, customers, the community and the environment in its main decisions.WHERE Strategic report.SIGN-OFF The board, as part of the strategic report.WHEN With the annual report, every financial year.
- Step 4: Modern slavery statementCOLLECT Supply chain structure, policies, due diligence and training, as the business chooses to describe them.WHERE Website, linked from the homepage.SIGN-OFF Approved by the board and signed by a director.WHEN For each financial year.
- Step 5: Gender pay gapCOLLECT Pay and bonus data for the six figures regulation 2 prescribes, taken on the snapshot date.WHERE Own website for at least three years, and the government’s reporting service.SIGN-OFF A written statement signed by a director or equivalent.WHEN Within 12 months of the 5 April snapshot date.
The order is our suggestion: site-level energy data first, because SECR, climate disclosure and UK SRS all draw on it.
The requirements in each row are the instruments’ own.
Requests
Who is asking for your ESG data, and on what authority
Most companies meet ESG reporting first as a request, not a statute: a customer’s supplier questionnaire, a tender question, a lender’s form or a rating platform’s portal.
What governs your answer depends entirely on who is asking and why.
Only one sender is limited by law: an EU customer that reports under the CSRD, asking a supplier that averaged 1,000 employees or fewer for information for that report.
Everyone else is governed by the contract, the tender or the platform’s method.
EcoVadis, for example, awards medals by percentile against every company it assessed in the previous twelve months, and a medal applies only to the entity assessed.
A request through CDP Supply Chain is a customer’s request in a different format, and the format does not change what the customer may require.
Some rows in any questionnaire map onto things UK law already makes you publish, such as a SECR figure or a modern slavery statement, and those are copied, never renegotiated.
The full method for a supplier pack is on the ESG questionnaire page, and what investors and rating agencies look at is on ESG criteria.
Who is asking · what governs the answer
Choose a sender.
Nothing you select leaves your browser.
Frameworks
The frameworks, and the two materiality tests
| Framework | Who it serves | Materiality | UK legal status |
|---|---|---|---|
| UK SRS S1 and S2 | Investors | Financial: could reasonably be expected to influence primary users’ decisions | Voluntary; comply or explain for five listing categories from 2027 |
| IFRS S1 and S2 | Investors | Financial | The ISSB baseline UK SRS was built from; not UK law |
| TCFD recommendations | Investors | Climate, financial | The basis of the current listing rule, replaced by UK SRS from 2027 |
| GRI Standards | All stakeholders | The organisation’s most significant impacts on the economy, environment and people | Voluntary; no UK instrument requires it |
| CDP | Investors and customers | Environmental disclosure on climate, forests and water | Voluntary |
| ESRS | Investors and stakeholders | Double: financial and impact | EU law, reaching UK groups through the CSRD |
One test or two
A UK-only reporter applies UK SRS’s financial materiality test, judged by effects on cash flows, access to finance and cost of capital.
A group reached by the CSRD may also have to run the EU’s double test; the difference is on double materiality and running a double materiality assessment.
Interoperability, not choice
Most groups reconcile two or three frameworks rather than choosing one.
The comparison is on ESG frameworks in the UK, the regulatory list on ESG standards, and the global picture on global sustainability standards.
Climate and carbon
Climate and carbon: where the regimes overlap most
Climate is the one subject that three UK regimes cover at once, which is why it is where reporting most often gets duplicated.
SECR asks for energy and emissions, the Companies Act asks for climate risk in the strategic report, and UK SRS S2 asks listed companies for the full climate standard.
All three trace back to the TCFD’s 2017 Final Report, with its four recommendations on governance, strategy, risk management and metrics and targets, and eleven recommended disclosures beneath them.
The TCFD disbanded on 12 October 2023, and the FSB asked the ISSB to monitor progress on climate disclosure, as the IFRS Foundation’s TCFD page records.
The FCA says its new rules replace the TCFD-aligned disclosures in the listing rules, so a listed company’s existing climate section is the starting point for its UK SRS S2 report (PS26/19 ¶1.10).
Carbon figures follow the GHG Protocol: Scope 1 is direct emissions from sources the company owns or controls, Scope 2 is purchased energy and Scope 3 is the rest of the value chain.
SECR asks a quoted company for global Scope 1 and 2, and an unquoted company or LLP for UK energy from gas, transport fuel and electricity, with no other Scope 3 category.
UK SRS S2 asks for Scope 3 too, subject to a one-year relief from initial application.
The factors for every UK figure are the government’s conversion factors for company reporting, republished each year.
The depth is on TCFD and UK SRS, UK SRS S2, the SECR reporting guide, SECR and the GHG Protocol; targets are on setting science-based targets.
Ratings
ESG ratings are opinions about your reporting
Most companies meet ESG ratings as a score they did not ask for, built mostly from what they publish.
The two best-known investor ratings are built on opposite principles.
MSCI says its ratings “are industry-relative measures” on a seven-band scale from AAA to CCC, so an AAA in one industry is not comparable with a BBB in another.
Sustainalytics measures unmanaged ESG risk, where lower is better, and says its categories are absolute, so a bank can be compared with an oil company.
A company can therefore be rated highly by one and as high risk by the other without either being wrong, and no mapping converts one into the other.
Neither is regulated today: under the ESG Ratings Order 2025, providing an ESG rating likely to influence an investment decision becomes a regulated activity, and providers need FCA authorisation from 29 June 2028.
A rating produced exclusively for accreditation or certification, and not to influence an investment decision, is excluded from that perimeter, which on our reading places supplier scorecards outside it.
The practical point is the same for every rater: a rating can only be as good as the published disclosure it reads, which is the strongest commercial reason to get the statutory disclosures complete.
What raters and investors look for, pillar by pillar, is on ESG criteria.
| MSCI ESG Ratings | Sustainalytics ESG Risk Ratings | |
|---|---|---|
| Basis | Industry-relative | Absolute across sub-industries |
| Scale | Seven bands, AAA to CCC | Negligible to Severe, by points of unmanaged risk |
| Better is | Higher | Lower |
| Compare across sectors? | No: relative to industry peers | Yes: the categories are absolute |
Oversight
Who checks UK ESG reporting, and how
No single regulator oversees ESG reporting, because no single duty creates it.
The FRC reviews annual reports, including their climate and SECR content, and has held the Companies Act power to apply to court for a defective report to be revised since 6 May 2021.
The auditor of the accounts states whether the strategic and directors’ reports are consistent with the accounts and prepared in accordance with the law, which is not assurance over the emissions figures.
The FCA supervises the listing rules, and says it will publish supervisory information on UK SRS reporting in the second half of 2027, ahead of the first reporting season (PS26/19).
The Environment Agency enforces ESOS through civil penalties, and the FCA polices sustainability claims by authorised firms through the anti-greenwashing rule.
Independent assurance is a choice: under the FCA’s final rules a listed company states whether it obtained assurance and on what basis, and the FRC’s ISSA (UK) 5000 governs engagements on periods from 15 December 2026 for those who commission one.
The regime-by-regime enforcement table is on ESG reporting requirements in the UK, and assurance on sustainability assurance.
What the law polices
Disclosure, not performance
None of the UK reporting duties sets a minimum standard of environmental or social performance.
A company can comply with SECR while reporting rising emissions, provided the figures are complete, the method is stated and the prior year is shown.
UK SRS works the same way: under comply or explain, a listed company that cannot yet disclose something says what is missing, why, and what it plans to do.
What the law does police is the accuracy of what is claimed.
For authorised firms, the FCA’s anti-greenwashing rule requires any reference to a product’s sustainability characteristics to be consistent with them and fair, clear and not misleading.
For companies under the UK Corporate Governance Code, Provision 29 asks the board to declare the effectiveness of material controls, which the FRC says include controls over narrative and ESG reporting.
The practical consequence is that the weakest part of most ESG reports is not what they leave out but what they assert without evidence.
Board-level ownership of that evidence is covered on ESG strategy, and how ESG differs from older corporate responsibility reporting on ESG vs CSR.
Order of work
If more than one duty applies, take them in this order
First, confirm what is already in force: SECR, climate disclosure and ESOS do not wait for anything, and neither do the modern slavery and gender pay duties.
Second, build one dataset rather than one per regime, because the energy, emissions and governance evidence is shared.
Third, if you are listed, plan the first UK SRS period now: the rules are final, the start date is fixed and the reliefs are known.
Fourth, answer questionnaires from that dataset, naming which regime, if any, obliges you, before deciding how much more to give.
The standards themselves are on UK SRS S1 and UK SRS S1 and S2, and the government’s UK SRS guidance and exposure draft consultation are the primary record.
What finished disclosures look like is on ESG reporting examples, and practitioner commentary sits on our sister site, srsreport.co.uk.
For the UK regime map as a whole, see UK sustainability reporting, or return to the UK SRS reference.
Frequently asked
ESG reporting, answered
What is ESG reporting?
ESG reporting is the disclosure of a company’s environmental, social and governance information, so that investors, customers and others can judge its risks and conduct.
In the UK it is not one report but several duties and voluntary practices, most of which sit inside the annual report: energy and carbon in the directors’ report, climate risk in the strategic report, and, for listed companies from 2027, UK SRS disclosures in the annual financial report.
Is ESG reporting mandatory in the UK?
For large and listed companies, much of it is.
SECR, climate-related financial disclosure, ESOS, modern slavery statements and gender pay gap reporting are in force.
The FCA’s final rules require companies listed in five categories to report against UK SRS or explain, for accounting periods beginning on or after 1 January 2027.
Smaller companies have no ESG reporting duty, though customers and lenders often ask for data.
How does ESG reporting relate to UK SRS?
UK SRS S1 and S2 are the UK’s investor-focused sustainability disclosure standards, published by the Department for Business and Trade on 25 February 2026 and based on the ISSB’s IFRS S1 and S2.
They are voluntary for everyone, and the FCA’s listing rules now ask listed companies in scope to report against them or explain.
They use financial materiality: information that could reasonably be expected to influence the decisions of the primary users of financial reports.
Is ESG reporting the same as sustainability reporting?
In practice, yes.
UK instruments use the word sustainability, as in UK Sustainability Reporting Standards and the FCA’s Sustainability Disclosure Requirements, and none of the UK reporting duties is called an ESG report.
A customer asking for sustainability reporting and one asking for ESG reporting usually want the same underlying data.
What frameworks are used for ESG reporting in the UK?
UK SRS, based on the ISSB standards, for investor-focused disclosure; the GRI Standards for reporting on a company’s most significant impacts; CDP for environmental disclosure requested by investors and customers; and the EU’s ESRS for groups reached by the CSRD.
The TCFD recommendations shaped all of them and are being replaced in the UK listing rules by UK SRS.
What is the FCA anti-greenwashing rule?
ESG 4.3.1R in the FCA Handbook requires every authorised firm to make sure any reference to the sustainability characteristics of a product or service is consistent with those characteristics and is fair, clear and not misleading.
It has applied since 31 May 2024 to communications with clients in the UK and to financial promotions made to people in the UK.
Is the UK regulating ESG ratings?
Yes, from 29 June 2028.
The Financial Services and Markets Act 2000 (Regulated Activities) (ESG Ratings) Order 2025, made on 15 December 2025, brings the provision of certain ESG ratings inside the FCA’s perimeter.
It regulates the firms that sell ratings, not the companies they rate, and the FCA consulted on its rules in CP25/34.
What is the difference between MSCI and Sustainalytics ESG ratings?
MSCI ESG Ratings are industry-relative, on a seven-band scale from AAA to CCC, so they compare a company only with its industry peers.
Sustainalytics ESG Risk Ratings measure unmanaged ESG risk on an absolute scale, where lower is better, so companies in different industries can be compared.
The two cannot be converted into one another, and a company can score well on one and poorly on the other.
Who checks ESG reports in the UK?
The FRC reviews annual reports and can apply to court for a defective report to be revised; the auditor of the accounts gives a consistency and legality opinion on the strategic and directors’ reports; the FCA supervises the listing rules; and the Environment Agency enforces ESOS.
Independent assurance over sustainability information is voluntary.
Does ESG reporting require a company to perform well on ESG?
No. None of the UK reporting duties sets a performance standard.
A company can comply while reporting rising emissions, provided the figures and narrative are complete and accurate.
What the law polices is the accuracy of claims: authorised firms are bound by the FCA’s anti-greenwashing rule, and every company’s annual report is subject to the Companies Act.
Can a customer require us to complete an ESG questionnaire?
Only as far as your contract allows, unless the customer reports under the EU’s CSRD.
For CSRD purposes, a supplier that averaged 1,000 employees or fewer is protected by the value chain cap: the customer must say which requested items exceed the voluntary standard and that the supplier may decline them.
Member states must transpose the cap by 19 March 2027.
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
The final rules: UK SRS on comply or explain for five listing categories, periods from 1 January 2027.
- Financial Conduct AuthorityPS26/19 (PDF), ¶¶1.2, 1.7, 1.10, 3.12, 3.14
The basis, the replacement of the TCFD rules, the start date and the reliefs.
- Financial Conduct AuthorityCP26/5 — the consultation
The proposals PS26/19 finalised, and changed.
- FCA HandbookUKLR 6.6 Annual financial report
Where the listing-rule disclosure duty sits.
- Department for Business and TradeUK SRS S1 and S2, and the UK SRS guidance
Published 25 February 2026 for voluntary use.
- Department for Business and TradeUK SRS S1 (PDF), ¶¶3, 17 and 18
The financial materiality test.
- legislation.gov.ukSI 2008/410 Schedule 7 (SECR)
Energy and carbon in the directors’ report.
- Department for Energy Security and Net ZeroSECR regulations: evaluation
About 19,900 organisations in scope.
- legislation.gov.ukThe Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 (SI 2022/31)
The 2022 climate disclosure duty for companies.
- Financial Conduct AuthoritySustainability Disclosure Requirements (SDR) regime
The four labels and the anti-greenwashing rule.
- FCA HandbookESG sourcebook, chapter 4 (ESG 4.1–4.3)
The labels, the restricted naming terms and the anti-greenwashing rule, ESG 4.3.1R.
- legislation.gov.ukThe FSMA 2000 (Regulated Activities) (ESG Ratings) Order 2025 (SI 2025/1349)
Authorisation for ESG ratings providers from 29 June 2028.
- MSCIMSCI ESG Ratings methodology
Industry-relative ratings on a seven-band scale, AAA to CCC.
- Morningstar SustainalyticsESG Risk Ratings
Absolute categories of unmanaged ESG risk, lower is better.
- FSB Task Force on Climate-related Financial DisclosuresFinal Report, June 2017, Figure 4
The four recommendations and eleven recommended disclosures.
- IFRS FoundationIFRS Foundation and the TCFD
The monitoring role the FSB asked the ISSB to take on after the TCFD disbanded.
- Greenhouse Gas ProtocolCorporate Accounting and Reporting Standard
The three scopes.
- Global Reporting InitiativeGRI Standards, GRI 1: Foundation 2021 §2.2
GRI’s test of the most significant impacts.
- EUR-LexDirective (EU) 2026/470 (Omnibus I)
The CSRD scope and the value chain cap.
- Financial Reporting CouncilUK Corporate Governance Code 2024
Provision 29 and ESG reporting controls.
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