What is ESG reporting?
ESG reporting is an organisation’s published account of environmental, social and governance matters: its energy use and emissions, its workforce and supply chain, and how it is governed.
In the UK it is not one document.
It is the sum of separate duties, such as SECR in the directors’ report, climate-related financial disclosure in the strategic report and the modern slavery statement on the website, plus any voluntary framework the organisation chooses.
What are ESG reporting requirements?
They are the legal duties that make an organisation publish or notify specific environmental, social or governance information.
Each has its own instrument, its own scope test, its own document and its own date.
In the UK the main ones are UK SRS for listed companies on a comply-or-explain basis, SECR, climate-related financial disclosure, ESOS, the modern slavery statement and gender pay gap reporting.
What are the ESG reporting requirements in the UK in 2026?
There is no single ESG report in UK law.
The duties are separate instruments: SECR energy and carbon reporting in the directors’ report (SI 2008/410 Schedule 7), climate-related financial disclosure in the strategic report (Companies Act 2006 sections 414CA and 414CB), ESOS energy audits notified to the Environment Agency, the Modern Slavery Act statement, gender pay gap reporting, and for listed companies the FCA’s listing rules, which move from TCFD to UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027 under PS26/19.
Is ESG reporting mandatory in the UK?
Parts of it are, for the organisations each regime catches.
SECR, climate-related financial disclosure, ESOS, the Modern Slavery Act statement and gender pay gap reporting are in force now.
UK SRS S1 and S2 are voluntary standards; the FCA’s final rules, published on 30 September 2026, require listed companies in five categories to report against them or explain why not.
Nothing requires a document called an ESG report.
Who has to report on ESG in the UK?
Each regime has its own test.
SECR reaches quoted companies at any size and unquoted companies and LLPs that do not meet two of its three “not more than” conditions (£36m turnover, £18m balance sheet, 250 employees).
Climate disclosure reaches named categories of company with more than 500 employees.
ESOS reaches undertakings with at least 250 employees, or with turnover over £44m and a balance sheet over £38m.
The FCA’s UK SRS rules reach companies listed in UKLR 6, 14, 15, 16 and 22, at any size.
Is UK SRS mandatory after the FCA’s decision?
In-scope listed companies must meet the FCA reporting obligation.
PS26/19 adopts a comply-or-explain approach across all of UK SRS, S2 included, for companies in five listing categories and for accounting periods beginning on or after 1 January 2027, with first reports in 2028.
The consultation had proposed mandatory S2 reporting; the final rules dropped it.
For every other UK entity the standards remain voluntary.
What was the UK ESG regulation of 2022?
The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022, SI 2022/31, in force for financial years beginning on or after 6 April 2022.
They amended sections 414C, 414CA and 414CB of the Companies Act 2006 to require eight climate-related disclosures from traded companies, banks, insurers, AIM companies and companies with turnover over £500 million, where they have more than 500 employees.
SI 2022/46 did the same for large LLPs.
Do private companies have ESG reporting requirements in the UK?
Large ones do, through regimes that test size rather than listing: SECR for unquoted companies that do not meet two of the three exemption conditions, climate disclosure for companies with turnover over £500 million and more than 500 employees, ESOS, the Modern Slavery Act statement at £36 million turnover and gender pay gap reporting at 250 employees.
No UK SRS requirement or threshold for private companies has been proposed.
Do SMEs have to do ESG reporting?
No UK statute requires a small or medium-sized company to publish an ESG report.
The pressure arrives through customers, lenders and tenders instead.
Where the customer reports under the EU’s CSRD and the supplier averages 1,000 employees or fewer, the value chain cap limits what the customer may require for that report, once its member state has transposed the rule, due by 19 March 2027.
What changed for SECR on 6 April 2025?
The Companies Act size limits rose, and SECR’s did not.
SI 2024/1303 raised the medium-sized ceilings to £54 million turnover and £27 million balance sheet, but SECR’s own table in SI 2008/410 Schedule 7 paragraph 20B still reads not more than £36 million, £18 million and 250 employees.
A company can therefore be medium-sized for its accounts and still inside SECR.
What is the ESOS Phase 4 deadline?
The qualification date is 31 December 2026 and the compliance date is 5 December 2027, both fixed by regulation 4 of the ESOS Regulations.
The Phase 4 action plan follows by 5 December 2028, with progress updates due on 5 December 2029, 2030 and 2031.
Does SECR require Scope 3 emissions?
Only very narrowly.
An unquoted company or LLP reports emissions from transport fuel, which can include some value chain travel, but no other Scope 3 category appears in Part 7A of Schedule 7.
A quoted company has no Scope 3 limb at all.
Listed companies meet Scope 3 instead under UK SRS S2 from 2027, after a one-year relief, on a comply-or-explain basis.
Does ESG reporting have to be assured in the UK?
No UK statute requires sustainability information to be assured, and SECR mentions no assurance.
The auditor of the accounts gives an opinion on whether the strategic and directors’ reports are consistent with the accounts and prepared in accordance with the law, which is not assurance over the figures.
Under the FCA’s final rules, a listed company states whether it obtained assurance and, if so, the provider, scope, level and standards.
What changed in ESOS Phase 4 in July 2026?
SI 2026/701, in force on 22 July 2026, removed Display Energy Certificates and Green Deal Assessments as compliance routes, added a report of savings achieved and a review of unimplemented action plan measures, added a third progress update due on 5 December 2031, and widened the ISO 50001 route to certification covering total or significant energy consumption.
The qualification thresholds did not change.
What is the penalty for missing a UK ESG reporting requirement?
It depends on the regime.
ESOS carries civil penalties set in Part 8 of its regulations, up to £50,000 for failing to undertake an energy audit plus £500 a working day for up to 80 working days, and publication.
SECR and climate disclosure create no penalty of their own; a defective report is dealt with under the Companies Act, including court-ordered revision.
The Modern Slavery Act duty is enforced by injunction, and gender pay gap failures are unlawful acts the Equality and Human Rights Commission can act on.
Social and governance
What are the social and governance requirements?
Modern slavery and gender pay gap for the S, the s.172(1) statement and the Code for the G.
Gender pay gap reporting counts employees on one day, 5 April, unlike the averages SECR and ESOS use.
The UK Corporate Governance Code 2024 adds no sustainability reporting duty, as its FAQ explains, but Provision 29 covers ESG reporting controls from 2026.
A carbon report does not discharge either social duty; each is set out on modern slavery reporting requirements and gender pay gap reporting requirements.
The S and the G
Modern slavery
The S and the G
Gender pay
The S and the G
Section 172
The S and the G
Controls