ESG reporting requirements UK: four regimes, four different scope tests
The ESG reporting requirements UK companies actually face are four separate statutes, not one ESG report.
SECR sits in the directors’ report and climate-related financial disclosure sits in the strategic report.
ESOS is an energy audit filed with the regulator, and UK SRS is published but not yet compulsory.
Three of the four are mandatory today, and each one tests your size in a different way.
Every figure below is cited to a named primary source, and every dated negative is stated as at 19 August 2026.
There is no single ESG reporting UK obligation, and nothing in statute asks for one
Four regimes, four filing homes, four scope tests.
Nothing joins them up for you.
Search for an ESG report and you will find a template; search the statute book and you will find four unrelated duties.
That gap is the single most expensive misunderstanding on this subject.
Each of those four lives in a different document, on a different clock, under a different regulator.
Three are compulsory today for the organisations they catch.
- The fourth, UK SRS, exists as a finished standard that nobody is yet obliged to use.
- Nothing in any of the four requires a document called an ESG report.
So “are ESG reports mandatory in the UK” has no single answer, only four.
The useful question is which of the four reach your particular group, which is what the scope checker below answers.
Notice what is missing from that picture: the S in ESG has no free-standing UK reporting statute at all.
Modern slavery and gender pay-gap reporting exist, but they are separate duties outside these four regimes.
What UK ESG reporting requirements actually means in law
Four phrases, one subject, and it is worth saying so plainly.
Definition, entities, requirements — in that order.
- ESG reporting requirements
- The statutory duties that make a UK organisation publish energy, emissions, climate or sustainability information.
- UK ESG reporting requirements
- The same four regimes, named from the UK end rather than the subject end.
- ESG regulations UK
- The instruments themselves: SI 2018/1155, SI 2022/31, SI 2022/46 and SI 2014/1643 as amended.
- ESG reporting UK
- The practice of meeting those duties, usually inside the annual report and accounts.
Those four search phrases mean the same thing, and treating them as different subjects is what produces four thin pages instead of one useful one.
The legal answer to all four is the same list of instruments.
SECR has no statute of its own, which surprises most people who go looking for one.
It is inserted text inside Schedule 7 to SI 2008/410, put there by SI 2018/1155.
Citing “the SECR Regulations” therefore cites the amending instrument rather than the operative law.
The official SECR guidance is Defra’s environmental reporting guidelines, last updated on 29 March 2019.
That is before the 2025 threshold uplift, before the 2026 evaluation, and before UK SRS existed.
That is the opposite of how most guidance on this subject treats it.
The ESG regulations UK companies actually report under, in one table
Four instruments, four filing homes, four different tests of size.
Read across the row rather than down the column.
Read that table once and the central point is obvious.
No two of the four use the same test, so a group can be caught by one and outside the other three.
That is why a single “are we in scope” answer does not exist for these regimes.
The detail behind each column sits on the SECR reporting guide, TCFD UK requirements and ESOS Phase 4 in full.
Which of the four ESG reporting requirements catch your group?
Three questions, and the whole check runs in your browser.
Nothing is sent anywhere.
Answer for the entity that actually files the accounts, not for the trading brand.
A group can sit in more than one answer, in which case run it twice.
The thresholds behind each answer are set out at who UK SRS actually catches and in SECR’s own thresholds in detail.
Are the entity’s securities admitted to the UK Official List, rather than to AIM or to no market at all?
Is the listing in UKLR 6, UKLR 16 or UKLR 22, rather than a secondary listing or a depositary receipt programme?
UKLR 14 is secondary listing and UKLR 15 is depositary receipts, and CP26/5 proposes a statement for those rather than a UK SRS report.
Does the entity exceed at least two of these three: turnover above £36m, balance sheet above £18m, more than 250 employees?
These are SECR’s own figures in Schedule 7 paragraph 20B, not the Companies Act size limits that rose on 6 April 2025.
Does the undertaking employ 250 or more people, or have turnover above £44m and a balance sheet total above £38m?
This is an OR between the headcount limb and a conjunctive financial limb, and never a two-of-three test.
A UKLR 6, 16 or 22 listing puts the entity in the 515 that CP26/5 proposes must comply with UK SRS S2.
That is a proposal, and no Policy Statement had been published as at 19 August 2026.
A UKLR 14 or 15 listing puts the entity among the 89 that CP26/5 would ask only for a statement.
The statement names the climate rules applying in the primary listing location, with no UK SRS duty proposed.
Exceeding two of £36m, £18m and 250 puts an unquoted company or LLP inside SECR.
The Companies Act size limits rose on 6 April 2025 and SECR’s own figures were not amended.
An unquoted company below two of the three SECR thresholds owes no energy and carbon disclosure.
The separate 40,000 kWh exemption only applies where the report states that as the reason.
The checker asks three questions because the four regimes only share two variables between them.
Listing status decides two of them, and size decides the other two on entirely different numbers.
SECR stopped meaning “large” on 6 April 2025
The Companies Act size limits went up by half.
SECR’s did not move.
For six years, “SECR catches large companies” was a harmless shorthand that happened to be true.
On 6 April 2025 it became a factual error, and most guidance on the open web has not caught up.
SI 2024/1303 came into force on 6 April 2025 and applies to financial years beginning on or after that date.
Regulation 10 raised the medium-sized ceilings; Schedule 7 paragraph 20B still reads £36m, £18m and 250.
The employee limb was not raised to 500 either, which is a separate error worth naming.
The practical consequence is a band of companies that are medium-sized for their accounts and still inside a mandatory energy and carbon regime.
The £40m company that is medium-sized and still in SECR scope
Schedule 7 Part 7A is drafted as a general application with exemptions.
That is what decouples it from the Companies Act.
Paragraph 20A applies the Part to unquoted companies, and paragraphs 20B and 20C then exempt the small ones.
A company is in scope if it exceeds at least two of turnover £36m, balance sheet £18m and 250 employees.
That worked example is ours, derived from the two instruments rather than quoted from either.
Both limbs are primary, and the arithmetic is the only thing we have added.
The gross and net pair for group parents is a genuine trap, and it appears on almost no competing page.
Quoted companies get the parallel wording without the words “in the United Kingdom”, consistent with reporting globally.
The narrower unquoted source list is the surprising one, because purchased heat and steam are outside it.
Full detail on all of that sits in what SECR asks you to disclose.
19,900 organisations — what DESNZ found when it counted
Scope came in 76% over forecast.
Cost came in roughly three times over.
The independent SECR evaluation, published 29 January 2026, records that DESNZ estimates approximately 19,900 organisations need to report.
That number is measured, and it supersedes every smaller figure still circulating in commentary.
Whether the £7,100 outturn and the £2,300 prediction share a price basis could not be confirmed.
Treat the three-times comparison as indicative rather than as a like-for-like figure.
The evaluation is unusually candid about whether any of this changed behaviour.
Only 25% of compliant respondents said SECR reduced energy use beyond other regulatory requirements.
Cite both ranges on non-compliance, because the narrowing is the interesting part.
The review’s recommendation is to retain SECR with amendments and consider proportionate refinements.
Scope 3 also remains outside SECR, and the call for evidence that closed in December 2023 added nothing.
The summary of responses was published on 21 November 2024 and no requirement followed.
The UK sustainability reporting requirements exist — the obligation does not, yet
The standards were finalised nine months ago.
What is still missing is the duty to use them.
UK SRS S1 and UK SRS S2 were issued by the Secretary of State for Business and Trade on 25 February 2026, alongside the government response.
Both are available for voluntary use by any entity that chooses to apply them.
So the UK sustainability reporting requirements now exist as published standards, without a duty attached.
The standards were created by assessing and endorsing the global baseline of IFRS Sustainability Disclosure Standards, as the FRC records.
S1 carries the general framework and general sustainability risks; S2 carries the climate requirements.
The GOV.UK guidance page is itself stale, still describing the FCA consultation as running until 20 March 2026.
Use the FCA’s own reporting-requirements page for the current position instead.
More on the standards themselves sits at UK SRS requirements and UK SRS S1 and S2.
The comparison with the EU regime is at CSRD vs UK SRS.
515 and 89: two routes out of CP26/5, and only one of them is UK SRS
Five listing categories are named in the consultation.
They do not all get the same obligation.
FCA CP26/5 was published on 30 January 2026 and closed on 20 March 2026.
Its cost benefit analysis at paragraph 43 splits the affected population in two, and most write-ups drop the split.
The 89 are being de-scoped rather than newly scoped, which is the opposite of how it is usually written up.
TCFD currently reaches them through UKLR 14.3.24R and 15.3.1R(3).
CP26/5 proposes that implementation would run for accounting periods beginning on or after 1 January 2027, if the rules are made.
It also proposes deleting the current TCFD-aligned climate disclosure rules, on the basis that UK SRS S2 broadly corresponds to them.
Never describe UKLR 15 as closed-ended investment funds, because that is UKLR 11 and CP26/5 excludes it by name.
Fuller detail sits at the 515 and the 89 and reporting against UK SRS.
The climate-disclosure duty is three instruments, not one
A Companies Act duty, a separate LLP duty, and an FCA Handbook rule.
Most pages name only the first.
The LLP climate-disclosure duty comes from SI 2022/46, and not from SI 2022/31, which does not reach LLPs at all.
It is a sister instrument that almost nobody names, and the mis-cite is one of the most common on this subject.
The in-scope categories are traded companies, banking companies, authorised insurance companies, insurance market participants, AIM companies and high-turnover companies.
A high-turnover company is one with turnover of more than £500 million, or aggregate group turnover above that figure.
SI 2022/733 added a mandatory portfolio alignment metric from 1 October 2022.
No 2025 or 2026 amendment to the pensions regime is recorded on legislation.gov.uk as at 19 August 2026.
The full treatment of this regime sits at climate-related financial disclosure and the UKLR comply-or-explain rule.
Pension-scheme trustees should read the CFD regime alongside their own scheme-year timetable.
The eight climate disclosures, and the one that says “scenarios”
Section 414CB(2A) lists eight items and no more.
Only one of them mentions scenarios at all.
Item (f) is the only one that mentions scenarios, and it asks for an analysis rather than a named pair.
Nothing in the regulations requires two scenarios, and nothing requires a 1.5°C and 3°C pairing.
The FCA has proposed to delete its current TCFD-aligned rules rather than converge them into UK SRS S2.
TCFD itself was disbanded on 12 October 2023, so nothing is being kept alive by that name.
ESOS is not a two-of-three test, and that catches groups out
One limb is a headcount.
The other is two money tests joined by AND.
Schedule 1 paragraph 1(a) of the ESOS Regulations defines a large undertaking two ways, and they are alternatives.
Either the undertaking employs at least 250 people, or it exceeds both money limbs together.
OR
turnover exceeding £44m AND balance sheet exceeding £38m
turnover £36m · balance sheet £18m · 250 employees
Putting those two side by side is the fastest way to see that they share nothing but the number 250.
The operator matters too: the money limbs read “in excess of”, while the headcount limb reads “250 or more”.
State the thresholds in sterling, because the euro figures ceased at IP completion day.
Employee counting follows paragraph 10: total persons employed each month, divided by the months in the accounting period.
legislation.gov.uk currently flags SI 2026/701 changes as pending application to Schedule 1.
Check the changes-to-legislation banner before quoting Schedule 1 as fully up to date.
ESOS changed on 22 July 2026, and most guidance predates it
Thirty-two regulations, made 23 June 2026.
Two compliance routes disappeared.
The Energy Savings Opportunity Scheme (Amendment) Regulations 2026 were laid on 1 July 2026 and came into force on 22 July 2026.
The explanatory memorandum says the instrument takes forward postponed changes from the 2021 consultation.
There is no net zero element in Phase 4, and the memorandum records that it was postponed again.
The government will consider introducing it after Phase 4, so any claim that Phase 4 adds a decarbonisation assessment is wrong.
Commentary saying participants must publish their own action plan is loosely worded.
The participant notifies the Environment Agency, and the administrator publishes each action plan and progress update.
Of these, only the notification and audit breaches carry the £500 daily penalty, capped at 80 working days.
Eighty working days at £500 is £40,000 on top of the initial penalty.
The publication penalty attaches to every category above, and it is the part commentary under-reports.
Your year end, your listing, your ESOS dates
The four regimes run on three different clocks.
Give it a year end and it does the arithmetic.
SECR runs on your financial year, so its first affected report is the next one you sign.
ESOS runs on a fixed compliance period that ignores your year end entirely.
Every ESOS date below is fixed in the regulations, and none of them move with your accounts.
Which month does the accounting period end in?
Is the entity listed in UKLR 6, 16 or 22, listed in UKLR 14 or 15, or not listed at all?
Does the undertaking meet the ESOS test on 31 December 2026, the Phase 4 qualification date?
Every fixed date between here and 2031, on one rail
Green is on the record, amber is proposed.
The rail carries the date; the reasoning sits beneath it.
The ESOS progress-update windows run by anniversary of the first day of the compliance period.
That is why Phase 3’s remaining updates fall on Phase 4’s clock, which is a genuine and common confusion.
The update must positively report the misses rather than only the hits.
Nobody else says this, and it is the part that turns a progress update from a formality into a disclosure.
SECR and ESOS ask for the same numbers, and so does everything else
Six data points cover the bulk of four disclosures.
Almost nobody collects them once.
The four regimes look unrelated on paper and draw on an almost identical underlying dataset.
Meter readings, fuel, fleet, floor area, spend and governance minutes do most of the work.
The ESOS audit is the one that forces a site-level view, and it is usually the missing piece.
A group that has done ESOS properly can answer most of SECR from the same asset register.
Conversion factors for all of this come from the government conversion factors, updated annually.
Scope 2 method choices follow the GHG Protocol Scope 2 Guidance, which SECR does not itself mandate.
Outside every regime, and inside everyone’s value chain
No UK ESG reporting duty reaches a small company directly.
That is not the same as being left alone.
Pressure arrives through contracts rather than through statute, and it arrives from four directions.
Understanding which one is asking tells you how much to give.
The cap is set by the Commission’s own voluntary standard, which is based on EFRAG’s VSME rather than identical to it.
Directive (EU) 2026/470 came into force on 18 March 2026 and narrowed the Corporate Sustainability Reporting Directive.
Both Article 40a figures come from recitals and from the Council, and the enacting article text could not be retrieved.
Treat the outcome as sound and do not attribute a block quote to the article itself.
The European Commission adopted its recommendation on the voluntary SME standard on 30 July 2025.
That standard stayed voluntary to apply and became binding as a limit, which is the whole of the SME story.
Build the inventory once, disclose it four times
Tell it which regimes reach you.
It works out what you are collecting twice.
Most groups run these four as four projects with four owners and four spreadsheets.
The duplication is not in the disclosures, it is in the collection underneath them.
The ESOS audit is usually the deepest dataset in the building, and it is usually the least reused.
Does the entity file a SECR energy and carbon disclosure?
Does it publish climate-related financial disclosures, under the Companies Act, SI 2022/46 or the UKLR?
Is the undertaking in ESOS Phase 4?
Whatever the answer, the sequence is the same: measure the sites, then the fuel, then the governance.
Every disclosure above is a view over that one dataset rather than a separate exercise.
Twenty-two things the rest of the internet has wrong about ESG reporting requirements UK
Every row on the left is live on a competing page today.
Every row on the right is a primary source.
This is the most citable block on the page, and it exists because the primary-source work was done first.
Each row is a self-contained answer with a named source behind it.
Twenty-two rows, and every one of them is currently live somewhere on the first page of results.
If you only take one thing from this page, take the row about 6 April 2025.
ESG reporting requirements UK — the questions people actually ask
Answered from the primary documents rather than from each other.
Every answer carries its source, verified 19 August 2026.
Four separate regimes, not one ESG report.
SECR puts energy and carbon in the directors’ report under Schedule 7 to SI 2008/410, and DESNZ measured 19,900 organisations in its scope.
Climate-related financial disclosure puts eight items in the strategic report under the Companies Act, with SI 2022/46 doing the same job for LLPs.
ESOS Phase 4 is an energy audit notified to the Environment Agency by 5 December 2027.
UK SRS S1 and S2 were published on 25 February 2026 and are voluntary, with the FCA proposing a duty for listed companies.
Three of the four are mandatory today for the organisations they catch.
SECR, climate-related financial disclosure and ESOS are all in force now.
UK SRS is published and voluntary, and the FCA has proposed making S2 compulsory for listed companies from accounting periods beginning on or after 1 January 2027.
That remains a proposal, and the FCA had published no Policy Statement as at 19 August 2026.
Each regime has its own test, and they share almost nothing.
SECR catches quoted companies with no size test at all, and unquoted companies and LLPs exceeding two of £36m turnover, £18m balance sheet and 250 employees.
Climate disclosure catches six named company categories with more than 500 employees, plus companies with turnover above £500m, under section 414CA.
ESOS catches undertakings with 250 or more staff, or turnover above £44m and a balance sheet above £38m.
UK SRS catches nobody compulsorily yet, though CP26/5 proposes a duty for 515 listed companies with 89 more on a lighter branch.
No UK ESG reporting duty reaches a small company directly.
SECR, climate disclosure and ESOS all target large or listed entities, and UK SRS is voluntary for everyone.
The pressure arrives through customer contracts instead, especially from customers preparing their own Scope 3 estimates.
Where the customer is an EU CSRD reporter, the value chain cap limits what it may demand.
CSRD does not apply directly to a UK-domiciled entity.
A UK group can still be reached as the subsidiary of an in-scope EU parent, or through an EU regulated-market listing.
The third-country route and a customer’s own data request are the other two ways in.
Directive (EU) 2026/470 narrowed the main CSRD test to a net turnover above €450 million and an average of 1,000 employees.
The third-country route uses €450 million for the parent and €200 million for the subsidiary or branch, with no employee test.
Collect the underlying data once and treat each disclosure as a view over it.
Six data points — consumption, emissions, transport, an intensity ratio, governance minutes and an asset register — do most of the work across all four regimes.
The ESOS audit produces the deepest site-level dataset in most groups, and it is usually the least reused.
The government conversion factors are the common denominator for every emissions figure.
Yes, for large ones, and the regime that catches them is SECR.
An unquoted company exceeding two of SECR’s three thresholds must publish energy and carbon information in its directors’ report.
Climate-related financial disclosure can also reach a private company through the high-turnover route above £500 million.
No UK SRS obligation is proposed for private companies at all.
The Companies Act size limits rose and SECR’s own thresholds were not amended.
SI 2024/1303 raised the medium-sized ceilings to £54m turnover and £27m balance sheet.
Schedule 7 paragraph 20B still reads £36m, £18m and 250.
A company can therefore be medium-sized for its accounts and still owe a SECR disclosure.
DESNZ estimates approximately 19,900 quoted companies, large unquoted companies and large LLPs.
That figure is in the independent evaluation published on 29 January 2026.
The original forecast of 11,300 and the £7,100 mean cost sit in the post-implementation review instead.
Smaller figures still circulating in commentary appear in no government document.
No, and this is the most commonly mis-stated point in the whole regime.
Paragraph 20D allows the omission only where the report states that low consumption is the reason.
A silent omission is not exempt and is simply a defective directors’ report.
For quoted companies the parallel wording drops the words “in the United Kingdom”.
Yes, and both duties come from separate instruments written for LLPs.
Part 3 of SI 2018/1155 requires a standalone energy and carbon report, because an LLP has no directors’ report.
The climate-disclosure duty for LLPs comes from SI 2022/46, not from SI 2022/31.
Naming the wrong instrument here is one of the most common errors on competing pages.
The compliance date is 5 December 2027, and the qualification date is 31 December 2026.
The action plan follows on 5 December 2028, with progress updates in 2029, 2030 and 2031.
The Environment Agency’s ESOS guidance is the operational reference for notification.
These dates are fixed in the regulations and do not move with your financial year.
It came into force on 22 July 2026 and changed six substantive things.
A third progress update was added, reports must carry more measure-level detail, and the payback-period calculation was removed.
The ISO 50001 exemption widened, participants must review the current action plan, and DECs and Green Deal Assessments stopped being compliance routes.
The explanatory memorandum also confirms there is no net zero element in Phase 4.
No, and this is widely sold as a Phase 4 feature.
The previous government postponed adding a net zero assessment, and the current one will consider it after Phase 4.
What Phase 4 does add is fuller reporting on measures proposed and implemented.
The Phase 4 guidance also requires the audit to cover 95% of total energy consumption.
No, the publication duty sits with the scheme administrator.
Regulation 10 requires the administrator to publish each action plan and each progress update.
The participant notifies, and regulations 34A and 34B contain no participant-facing publication requirement.
Commentary saying otherwise is loosely worded rather than plainly wrong.
No start date has been set, because no rule has been made.
The standards themselves were published on 25 February 2026 for voluntary use.
CP26/5 proposes that reporting would begin with accounting periods beginning on or after 1 January 2027, if the rules are made.
The FCA intends to publish a Policy Statement in autumn 2026.
The FCA proposes to delete its TCFD-aligned rules rather than converge them.
Paragraph 4.4 of CP26/5 says UK SRS S2 broadly corresponds with the TCFD recommendations, so deletion is appropriate.
The current rule is UKLR 6.6.6R(8), applied onward to the other listing categories.
TCFD itself was disbanded on 12 October 2023 and its work moved to the ISSB.
Yes, under a separate DWP regime tested on scheme assets.
SI 2021/839 caught schemes with £5 billion of relevant assets from October 2021 and £1 billion from October 2022.
Master trusts and collective money purchase schemes are caught regardless of size.
Requirements cease once relevant assets fall below £500 million.
It depends entirely on which regime you missed.
ESOS carries the sharpest sanctions, and Part 8 of the ESOS Regulations sets every amount.
Failing to undertake the audit draws £50,000, or such lesser amount as the compliance body may determine.
On top of that runs £500 for each working day, to a maximum of 80 working days.
Regulation 45 was amended by regulation 29 of SI 2026/701, and the consolidated page still shows the superseded text.
A publication penalty attaches to every ESOS category, and that is the real deterrent.
SECR and climate disclosure sit inside the annual report, so the sanction is the general Companies Act regime for defective accounts.
On GOV.UK, and it is seven years old.
The SECR collection page and the environmental reporting guidelines are the official material.
The guidelines were last updated on 29 March 2019, before the threshold uplift and before UK SRS existed.
Read the guidance for method and the regulations for scope.
Every source on this page, numbered and linked
Each entry below is linked by name somewhere in the text above, so a claim can be traced without counting brackets.
Legislation and regulator documents carry the load, and commentary is not used for any fact a primary source states.
- The Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 — SI 2018/1155 — the instrument that created SECR, in force for financial years beginning on or after 1 April 2019
- Schedule 7 to the Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008 — SI 2008/410 — the directors’ report schedule that SECR inserts its energy and carbon requirements into
- Environmental reporting guidelines, including SECR guidance — GOV.UK / Defra. The official method guidance, last updated 29 March 2019 — before the size-threshold uplift and before UK SRS existed
- UKLR 6.6.6R(8) — FCA Handbook. The climate-related financial disclosure statement owed by commercial companies with an equity shares listing
- The Companies (Accounts and Reports) (Amendment and Transitional Provision) Regulations 2024 — SI 2024/1303 — the company size uplift for financial years beginning on or after 6 April 2025; it did not amend the SECR thresholds
- Schedule 7, paragraph 20B — SI 2008/410. SECR’s own two-of-three size test — turnover above £36m, balance sheet above £18m, more than 250 employees
- Streamlined Energy and Carbon Reporting regulations: evaluation — GOV.UK / DESNZ, 29 January 2026. The measured population of organisations in SECR scope
- 2026 post-implementation review of the SECR Regulations 2018 — GOV.UK / DESNZ, 26 May 2026. The document that carries the original 11,300 forecast and the £7,100 mean ongoing cost
- SECR post-implementation review — full report (PDF) — DESNZ. The underlying report behind the review landing page
- UK greenhouse gas emissions reporting: Scope 3 emissions — GOV.UK / DESNZ call for evidence and summary of responses on whether to extend mandatory Scope 3 reporting
- Government response to the consultation on UK Sustainability Reporting Standards — GOV.UK / DBT, 25 February 2026. The response published alongside UK SRS S1 and S2; Annex A records the UK-specific amendments
- UK Sustainability Reporting Standards — GOV.UK guidance page. UK SRS S1 and S2 are available for voluntary use; no reporting obligation attaches to them
- Climate-related reporting requirements — FCA. The regulator’s own statement of what listed issuers owe today, and of what remains proposed
- CP26/5: aligning listed issuers’ sustainability disclosures with international standards — FCA, published 30 January 2026, closed 20 March 2026. Proposals only; no Policy Statement had been published as at 19 August 2026
- FCA CP26/5 consultation paper (PDF) — FCA. The full paper, including the Cost Benefit Analysis whose paragraph 43 carries the 515 and 89 split
- The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 — SI 2022/31 — the climate-disclosure duty for companies; the test is more than 500 employees with the turnover route above £500m
- The Limited Liability Partnerships (Climate-related Financial Disclosure) Regulations 2022 — SI 2022/46 — the separate instrument that brings LLPs into climate-related financial disclosure. It is not SI 2022/31
- Companies Act 2006, section 414CA — The duty to prepare a non-financial and sustainability information statement
- The Companies (Strategic Report) (Climate-related Financial Disclosure) (Amendment) Regulations 2022 — SI 2022/733 — the amending instrument
- Companies Act 2006, section 414CB — The content of the non-financial and sustainability information statement, including the eight climate-related disclosures
- The Energy Savings Opportunity Scheme Regulations 2014, Schedule 1 — SI 2014/1643 — the ESOS qualification test: 250 or more employees, or turnover above £44m and balance sheet total above £38m
- The Energy Savings Opportunity Scheme (Amendment) Regulations 2026 — SI 2026/701, in force 22 July 2026. Removed the DEC and Green Deal assessment routes, widened the ISO 50001 exemption, and added a third progress update
- ESOS Regulations 2014, regulation 34B — SI 2014/1643. The action plan requirement
- Government conversion factors for company reporting — GOV.UK / DESNZ. The UK emission factors, republished annually, that SECR and UK SRS reporting both draw on
- GHG Protocol Scope 2 Guidance — Greenhouse Gas Protocol. The dual location-based and market-based reporting requirement for purchased electricity
- Council signs off simplification of sustainability reporting and due diligence requirements — Council of the European Union, 24 February 2026. States that member states have one year after entry into force to transpose
- Directive (EU) 2026/470 — EUR-Lex. The Omnibus I directive amending CSRD; the adopted scope test is 1,000 or more employees and net turnover above €450m
- Schedule 7, Part 7 — SI 2008/410. The energy and carbon report content requirements, including the intensity ratio and the narrative on energy efficiency action
- Additional explanatory information regarding the value chain cap — European Commission, 6 May 2026. The limit on what a large reporter may demand from a smaller undertaking in its value chain
- SECR regulations evaluation report (PDF) — DESNZ, January 2026. The independent evaluation behind the published population figure
- Schedule 7, paragraph 20D — SI 2008/410. The low-energy exemption — available only where the report states that the undertaking consumed 40,000 kWh or less
- SI 2018/1155, Part 3 — The limited liability partnership energy and carbon report provisions
- Energy Savings Opportunity Scheme (ESOS) — GOV.UK / Environment Agency. The scheme administrator’s guidance for participants
- Explanatory memorandum to SI 2026/701 (PDF) — The memorandum accompanying the 2026 ESOS amendment, recording what each change does and why
- How to comply with ESOS Phase 4 — GOV.UK / Environment Agency. The Phase 4 compliance route, qualification date and notification deadline
- ESOS Regulations 2014, regulation 10 — SI 2014/1643. Places the publication duty for action plans and progress updates on the scheme administrator
- UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 — GOV.UK / DBT, 25 February 2026. The standards themselves, as published
- UK Listing Rules sourcebook — FCA Handbook. The listing categories — UKLR 6, 14, 15, 16 and 22 — that decide which route an issuer sits on
- The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2021 — SI 2021/839 — the earlier instrument in the climate-disclosure sequence
- ESOS Regulations 2014, Part 8 — SI 2014/1643, regulations 39 to 47. The civil penalties, including £50,000 — or such lesser amount as the compliance body may determine — for failing to undertake an energy audit, plus £500 for each working day to a maximum of 80 working days. Regulation 45 was amended by regulation 29 of SI 2026/701, and the consolidated page still shows the superseded text
- Streamlined Energy and Carbon Reporting — GOV.UK collection page. The government’s landing page for SECR guidance and related publications
- Directive (EU) 2022/2464 — the Corporate Sustainability Reporting Directive — EUR-Lex. The CSRD as originally adopted, before Omnibus I narrowed its scope
- Sustainability reporting — EFRAG. The technical adviser that develops the European Sustainability Reporting Standards
- Sustainability reporting developments: frequently asked questions — FRC. Records that a new or amended ISSB standard requires UK endorsement before it enters UK SRS
- Companies Act 2006, section 465 — The company size definition whose limits rose on 6 April 2025 — and which SECR’s own thresholds are not tied to
- The Energy Savings Opportunity Scheme Regulations 2014 — SI 2014/1643, as amended. The scheme in full, including the qualification, audit and notification duties
Verified 19 August 2026 against the documents as published on that date.
The four regimes, each in its own depth
This page is the map, and each regime has a page that works it through in detail.
The question worth settling first is which of the four regimes reaches you at all.
See whether UK SRS reaches you Or start with SECR — the one that already applies to most large groupsUKSRS — independent reference on UK ESG reporting requirements.
Every figure on this page is cited to a named, dated primary source.