UK SRSThe UK Sustainability Reporting Standards, ESOS, SECR and TCFD, read against the published text.HUBYOU ARE HEREUK SRS GuideAn independent reference guide to UK SRS, ESG, TCFD, SECR, ESOS and the global standards.Global Reporting StandardsSustainability reporting standards worldwide: ISSB, the EU CSRD after Omnibus I, California SB 253 and SB 261, and UK SRS.UK SRS StandardsUK SRS S1 and S2 at the provision: reliefs, comply or explain, and the FCA statements.ESOS QuestESOS Phase 4 in depth: qualification, the audit, sign-off, action plans and penalties, read against the Regulations.SRS EngineeringThe data build behind a UK SRS report: metrics, owners, controls and timing.SRS ReportWhat a UK SRS report contains, how it is assembled, and how to read one.UK SRS ReportAnalysis and commentary: CDP, the DESNZ emission factors, SECR and ESOS, with every figure cited.UK SRS NewsThe cluster's news publication, and what a UK SRS report contains.UK SRS DeliveryTemplates, costs, ESOS delivery guides and readiness assessment.UK SRS FinanceFinanced emissions, PCAF and IFRS S1/S2 for banks, insurers and asset managers.SECRStreamlined Energy and Carbon Reporting: deadlines, thresholds, eligibility and guidance.Carbon CreditsCarbon credit ratings, risk analysis, valuation and market structure.Environmental RegimesThe eight UK environmental reporting regimes, their thresholds, deadlines and regulators.UK SRS ServicesThe services arm: ESOS, SECR, net zero and sustainability consultancy.

ESG reporting · UK requirements

ESG reporting requirements in the UK

There is no single ESG report in UK law.

Fourteen separate regimes reach UK organisations instead, among them UK SRS for listed companies, SECR, climate-related financial disclosure, ESOS, the modern slavery statement and gender pay gap reporting.

Each has its own test, document and date, so the work is finding the ones that reach you.

Fourteen duties

What are the ESG reporting requirements in the UK?

Fourteen separate regimes, grouped by who they reach; PPN 006 is a bidding condition and CSRD is EU law.

Listed companies come first, then the duties most large companies and LLPs meet, then those that reach particular sectors or bidders.

The FCA’s own summary of what listed issuers owe is on its reporting requirements page.

Every framework, voluntary ones included, is on sustainability reporting requirements in the UK.

  1. Listed companies · periods from 1 January 2027

    UK SRS

    Companies in UKLR 6, 14, 15, 16 and 22 report against S1 and S2 in the annual financial report, or explain why not (FCA PS26/19).

    UK SRS requirements

  2. Large companies and LLPs · since April 2019

    SECR energy and carbon

    Quoted companies at any size, and unquoted companies and LLPs that exceed two of £36m turnover, £18m balance sheet and 250 employees, report energy and emissions in the directors’ report (SI 2008/410 Sch 7), or for an LLP in a separate energy and carbon report (SI 2008/1911 reg 12B).

    SECR requirements

  3. More than 500 employees · since April 2022

    Climate-related financial disclosure

    Traded companies, banks, insurers, AIM companies and companies over £500m turnover make eight climate disclosures in the strategic report (CA 2006 s.414CA).

    CFD requirements

  4. s.172: above the medium-sized test · NFSI: more than 500 employees

    Section 172(1) and NFSI statements

    The strategic report says how the directors had regard to the community and the environment (CA 2006 s.414CZA); in the non-financial and sustainability information statement, the five s.414CB(1) matters apply only to traded, banking and insurance companies with more than 500 employees, and AIM and high-turnover companies give the climate disclosures alone (s.414CB).

    Non-financial reporting requirements

  5. 250 staff, or £44m and £38m · Phase 4 due 5 December 2027

    ESOS energy audit

    Large undertakings audit their energy use, or hold ISO 50001, and notify the Environment Agency (SI 2014/1643).

    ESOS requirements

  6. £36m turnover · every financial year

    Modern slavery statement

    Suppliers of goods or services publish a signed statement on their website, linked from the homepage (MSA 2015 s.54).

    Modern slavery requirements

  7. 250 employees on 5 April · within 12 months

    Gender pay gap

    Private and voluntary employers publish six pay and bonus figures on their own site and the government’s service (SI 2017/172).

    Gender pay gap requirements

  8. Pension schemes of £1bn or more · seven months after year end

    Pension scheme climate report

    Trustees, and authorised master trusts and CDC schemes at any size, publish a climate report (SI 2021/839).

    Pension scheme climate requirements

  9. Authorised firms · since 31 May 2024

    FCA SDR and anti-greenwashing

    Every sustainability claim must be fair, and fund managers using a label make product and entity disclosures (FCA ESG sourcebook).

    SDR requirements

  10. Covered installations, aircraft and ships · report by 31 March

    UK ETS

    Operators submit a verified emissions report and surrender allowances by 30 April (SI 2020/1265).

    UK ETS requirements

  11. Producers over £1m and 25 tonnes · large report by 1 April and 1 October, small by 1 April

    Packaging EPR

    Small and large producers report packaging data through the government’s service (SI 2024/1332).

    Packaging EPR requirements

  12. Importers of CBAM goods · tax from 1 January 2027

    UK CBAM

    Importers at £50,000 or more in a rolling year register, file returns and pay HMRC (Finance Act 2026 Part 5).

    CBAM requirements

  13. Government bids over £5m a year · a procurement condition

    Carbon reduction plan

    Suppliers publish Scope 1, Scope 2 and five Scope 3 categories with a net zero commitment by 2050 (PPN 006).

    Carbon reduction plan requirements

  14. EU subsidiaries over 1,000 staff and €450m · years from 2027

    CSRD, for UK groups

    The EU entity publishes an ESRS sustainability statement with limited assurance (Directive (EU) 2026/470).

    CSRD requirements

Status

Is ESG reporting mandatory in the UK?

Parts of it are.

The law reaches you duty by duty, never as “ESG”.

UK SRS is no longer simply voluntary pending future rules.

Since PS26/19 on 30 September 2026, listed companies in UKLR 6, 14, 15, 16 and 22 report against it or explain why not, for periods beginning on or after 1 January 2027.

SECR does not catch a company for having more than 250 employees, or more than £36m turnover, or more than £18m on its balance sheet.

It catches a large unquoted company that exceeds two of those three, because paragraph 20B exempts any that meets two of the “not more than” conditions, and an LLP on the same figures under SI 2008/1911 reg 12B.

An ESG disclosure

Required by statute

SECR, climate disclosure, ESOS, modern slavery, gender pay gap, the s.172(1) statement, pension scheme reports, UK ETS, UK CBAM and packaging EPR.

PPN 006 is a condition for bidders on in-scope government contracts, not a statute.

Comply or explain

UK SRS for UKLR 6, 14, 15, 16 and 22, and the Code’s Provision 29.

Report, or say what is missing and why.

Voluntary

UK SRS for everyone else, GRI, TNFD and CDP.

Often asked for by customers, lenders and investors.

FCA PS26/19 · DBT UK SRS guidance

One company, test by test

What does this look like for one manufacturer?

An AIM-traded manufacturer with 600 staff, £120m turnover and a £60m balance sheet owes six duties, and UK SRS is not one of them.

It is an illustration, not a real organisation.

A private LLP with 300 staff and £40m turnover owes SECR (SI 2008/1911 reg 12B), ESOS, gender pay gap reporting and, if it supplies goods or services, the slavery statement, but not climate disclosure, which reaches an LLP like it only above 500 employees and £500m turnover.

A UKLR 6 commercial company with 2,400 staff owes all of it, plus UK SRS on comply or explain and the Code’s Provision 29.

The seven scope tests behind these answers, and their operators, are in the reference below.

  1. 1

    Is it in a UKLR category?

    No: AIM is not on the Official List, so none of UKLR 6, 14, 15, 16 or 22 applies, and UK SRS stays voluntary for it.

  2. 2

    Does SECR reach it?

    Yes: AIM makes it unquoted for SECR, and it exceeds all three of £36m, £18m and 250, so Part 7A applies (Sch 7 ¶20B).

  3. 3

    Climate-related financial disclosure?

    Yes: the AIM limb of s.414CA(1)(e) applies, and it has more than 500 employees.

  4. 4

    ESOS?

    Yes: it has at least 250 employees (Sch 1), so it notifies by 5 December 2027.

  5. 5

    The social duties?

    Yes: £120m is above the £36m slavery threshold (SI 2015/1833), and 250 or more employees on 5 April bring gender pay gap reporting (SI 2017/172).

  6. 6

    A section 172(1) statement?

    Yes: it exceeds the medium-sized limits of £54m, £27m and 250 (s.414CZA), so six duties in all.

  7. 7

    Anything else?

    Not on these figures: packaging EPR turns on tonnage handled, UK CBAM on imports, UK ETS on covered installations and PPN 006 on bids for government contracts.

Why can 250 employees trigger ESOS but leave a company exempt from SECR?

The employee tests use different operators: ESOS starts at 250, while an unquoted company’s SECR size exemption includes an average of exactly 250.

This fictional size-test comparison uses a standalone UK unquoted company with £40 million turnover and a £15 million balance sheet.

Assume the figures and employee result hold for the relevant two consecutive financial years, with no parent or group complication.

Sources: SI 2008/410 Schedule 7 paragraph 20B(1)–(3) · SI 2014/1643 Schedule 1 paragraphs 1, 1A, 9–11.
Employee resultSECR size testESOS size test
Exactly 250 under each regime’s own counting rulesExempt: both the £15m balance sheet and 250 employees satisfy the “not more than” conditionsMeets the employee limb: at least 250 is enough
251 under each regime’s own counting rulesNot size-exempt on these stable figures: turnover and headcount both exceed the SECR limitsStill meets the employee limb

These are size-test results, not a complete compliance opinion: count employees under each instrument and check the relevant period, qualification date and any relief separately.

For the period and relief checks, use SECR reporting requirements and the ESOS Phase 4 guide.

Penalties

What happens if a company misses an ESG reporting duty?

ESOS, pension scheme reports and the UK ETS carry penalties of their own; SECR and climate disclosure are enforced through the Companies Act.

Sources: SI 2014/1643 Part 8 · CA 2006 s.419(3) and s.414D · CA 2006 s.456 and SI 2021/465 art 4 · SI 2008/1911 · PS26/19 · SI 2021/839 reg 9 · SI 2017/172 · MSA 2015 s.54(11) · SI 2020/1265 art 52
RegimeSanctionWho acts
ESOSUp to £50,000 for a missed audit, plus £500 a working day for up to 80 working days, and publicationThe Environment Agency
SECR and climate disclosureNo penalty in the instruments; a defective report can be revised by court order under s.456The Financial Reporting Council
Company directorsAn offence to approve a directors’ or strategic report knowing it does not comply, or reckless as to that, and failing to take reasonable steps to prevent itProsecution under CA 2006 s.419(3) and s.414D
SECR, LLPsOffences for members who fail to secure, or approve a defective, energy and carbon reportThrough SI 2008/1911
UK SRSA listing-rule obligation; supervisory information planned for the second half of 2027The FCA
Pension scheme climate reportA mandatory penalty of at least £2,500 for failing to publishThe Pensions Regulator
Gender pay gapAn unlawful actThe Equality and Human Rights Commission
Modern slavery statementAn injunction; no fineThe Secretary of State
UK ETSAn excess emissions penalty for each allowance not surrenderedThe scheme regulator
Who actsExplore

Who acts

Environment Agency

ESOS: up to £50,000 for a missed audit, plus £500 a working day for up to 80 working days, and publication.

Deadlines

When are the UK ESG reporting deadlines?

The next are 31 December 2026 (ESOS qualification), 1 January 2027 (UK SRS periods begin) and 5 December 2027 (ESOS compliance).

SECR and climate disclosure run on the financial year, UK SRS on the accounting period, and ESOS on a four-year cycle that ignores the year end, each date fixed in an instrument.

  1. 30 September 202601

    FCA publishes PS26/19

    UK SRS on comply or explain for five listing categories.

    PS26/19

  2. 31 December 202602

    ESOS Phase 4 qualification date

    The undertaking and its UK group take the size test on this day.

    ESOS Phase 4 guidance

  3. 1 January 202703

    FCA UK SRS rules apply; UK CBAM starts

    Accounting periods beginning on or after this date report against S1 and S2 or explain, with Scope 3 and climate-first reliefs; the UK CBAM tax on imports begins.

    PS26/19 Appendix 1, UKLR TP 16 · Finance Act 2026 Part 5

  4. 19 March 202704

    EU transposition deadline for the value chain cap

    Member states bring the Omnibus I changes into national law.

    Directive (EU) 2026/470

  5. 5 December 202705

    ESOS Phase 4 compliance deadline

    Complete the audit or certification route and notify the Environment Agency.

    ESOS Phase 4 guidance

  6. 1 January 202806

    UK CBAM registration opens

    Anyone who triggered registration during 2027 registers by 31 January 2028.

    Finance Act 2026 Part 5

  7. Periods beginning in 202807

    Only climate-first relief continues

    The Scope 3 relief ends, and first UK SRS reports for 2027 periods are published in 2028.

    PS26/19 ¶3.12 and UKLR TP 16

  8. 5 December 202808

    ESOS Phase 4 action plan due

    Progress updates follow on 5 December 2029, 2030 and 2031.

    ESOS regulation 34B

  9. Periods beginning in 202909

    FCA transitional reliefs end

    The comply-or-explain obligation continues across S1 and S2; the end of the reliefs is not a new mandate.

    UKLR TP 16.4R–16.7R

Listed companies

What do listed companies have to report from 2027?

UK SRS S1 and S2 on comply or explain, with reliefs in the first two years.

The Department for Business and Trade published UK SRS S1 and S2 on 25 February 2026, for voluntary use by any entity under its UK SRS guidance.

The FCA turned them into a duty for companies in five UK Listing Rules categories: UKLR 6, 14, 15, 16 and 22.

The first periods begin on or after 1 January 2027, and first reports follow in 2028 (PS26/19 ¶3.12).

A company reports against S2 and S1, or says what it has not met, why, and what it will do.

The rule text, the explain statement and every relief are on UK SRS reporting requirements.

More: who is in scope · the FCA rule · scope and thresholds · UK SRS reporting · UK SRS compliance · UK SRS S1 and S2

202720282029 on
Scope 3 relief
Leave out Scope 3 under S2 for the first year, by saying so.
Climate-first relief
Report S1 on climate only for the first two years.
Comply or explain
Continues when the reliefs end; their end is not a new mandate.

PS26/19 ¶3.14 and UKLR TP 16

Private companies and LLPs

What do large private companies and LLPs have to report?

SECR first, climate disclosure above 500 employees, then the strategic-report statements.

SECR’s size test is its own, and the 2025 uplift to the Companies Act limits did not move it.

Above 500 employees, climate-related financial disclosure adds eight disclosures to the strategic report.

Every SECR paragraph and the 40,000 kWh relief are on SECR reporting requirements, and the climate duty on CFD reporting requirements.

More: SECR reporting guide · SECR · climate-related financial disclosures · TCFD in the UK · non-financial reporting requirements · ESG reporting in practice · sustainability reporting · ESG consultancy · ESG reporting consultants

£40m · £20m · 200 staff

Companies Act: medium-sized

Under the £54m turnover and £27m balance sheet ceilings in force since 6 April 2025, so it is medium-sized for its accounts.

SECR: still in scope

It exceeds £36m and £18m, two of SECR’s three, so it reports energy and carbon in the directors’ report.

CA 2006 s.465 · SI 2024/1303 · Sch 7 ¶20B

ESOS

Is ESOS part of ESG reporting?

It is an energy audit and a notification, not a disclosure.

ESOS is never printed in the accounts: the participant tells the Environment Agency it has done the work.

Its size test is an “or”, not two of three: Schedule 1 asks for 250 employees, or both money limbs exceeded.

SI 2026/701, in force since 22 July 2026, removed Display Energy Certificates and Green Deal Assessments as routes, widened the ISO 50001 route, and added a report of savings achieved, a review of unimplemented measures and a third progress update.

What the notification holds, the action plan and the progress updates are on ESOS reporting requirements.

More: ESOS Phase 4 in full · ESOS deadlines · the ESOS guide · ESOS vs SECR

  1. 31 December 2026

    Qualify

    At least 250 employees, or turnover over £44m and a balance sheet over £38m.
  2. 5 December 2027

    Notify compliance

    An audit covering 95% of energy use, or ISO 50001.
  3. 5 December 2028

    Notify the action plan

    The scheme administrator publishes it.
  4. 2029, 2030 and 2031

    Three progress updates

    The third was added by SI 2026/701.

Environment Agency Phase 4 guidance · reg 34B

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.

Sources: MSA 2015 s.54 and SI 2015/1833 · SI 2017/172 · CA 2006 s.414CZA · UK Corporate Governance Code 2024
DutyWho it reachesWhenWhere
Modern slavery statementSuppliers of goods or services with total turnover of at least £36m, counting subsidiariesEach financial yearWebsite, linked from the homepage
Gender pay gapPrivate and voluntary employers with 250 or more employees on 5 AprilWithin 12 months of the snapshotOwn website and the government’s service
Section 172(1) statementCompanies above the medium-sized test of £54m, £27m and 250Each financial yearStrategic report
Provision 29 declarationCommercial companies and closed-ended funds, on comply or explainYears from 1 January 2026Annual report
The S and the GExplore

The S and the G

Modern slavery

A statement each financial year from suppliers of goods or services with total turnover of at least £36m, counting subsidiaries.

The EU

Does the EU’s CSRD reach UK companies?

Not in its own right, but it can reach a UK group three ways.

The Corporate Sustainability Reporting Directive reaches a UK group through an EU subsidiary in scope, an EU listing, or the third-country route in Article 40a.

Directive (EU) 2026/470 narrowed the main test to undertakings exceeding both 1,000 employees and €450m, for years from 1 January 2027, after the Council’s sign-off.

A CSRD reporter may not require a supplier averaging 1,000 employees or fewer to provide more than the voluntary standard’s capped datapoints.

The Commission’s explanatory note says a customer asking for more must say so, and the supplier may decline.

The routes, the revised ESRS and the timing are on CSRD reporting requirements for UK groups.

More: ESG questionnaire · VSME · CSRD vs UK SRS

A UK group

An EU subsidiary in scope

One exceeding both 1,000 employees and €450m net turnover, for years from 1 January 2027.

An EU listing

Securities on an EU regulated market, which from 2027 bring the issuer in only on the same 1,000-employee and €450m test.

Article 40a

A non-EU parent with over €450m of EU turnover in each of the last two years, and an EU subsidiary or branch over €200m, from 2028; no headcount test.

Directive (EU) 2026/470, Arts 19a and 40a as amended

Your organisation

Which requirements apply to your organisation?

Four facts decide it: legal form, listing, turnover and headcount.

One year’s figures · eight UK duties

Legal form

5 of 8 tests point to a duty on these figures.

UK SRS · FCA PS26/19

No UK SRS duty for this category or for an unlisted entity.

The standards remain available for voluntary use.

SECR · Sch 7 ¶20B (unquoted company)

Fewer than two conditions are met, so these figures point to a SECR duty: UK energy, emissions and an intensity ratio in the directors’ report.

Climate disclosure · CA 2006 s.414CA

At or under the 500-employee floor, which applies to every limb, so this duty does not arise.

ESOS · SI 2014/1643 Sch 1

The large-undertaking test is met.

For Phase 4 it is taken on 31 December 2026 across the UK group, with compliance notified by 5 December 2027.

Modern Slavery Act 2015 s.54

Total turnover is not less than £36 million, so a supplier of goods or services publishes a slavery and human trafficking statement each financial year.

Subsidiaries’ turnover counts.

Gender pay gap · SI 2017/172

250 or more employees: a private or voluntary-sector employer publishes six figures within 12 months of the 5 April snapshot date.

The count is taken on that date, not as an average.

Section 172(1) statement · CA 2006 s.414CZA

Larger than medium-sized on these figures, so the strategic report includes a statement of how the directors had regard to s.172(1)(a)–(f), including the environment.

UK Corporate Governance Code 2024

Not applicable: the Code reaches the commercial companies and closed-ended investment funds categories only.

One year, one entity, literal readings.

It does not aggregate groups, apply the two-year rules or the ESOS snapshot date.

Nothing you enter leaves your browser.

The result is a starting point: group rules, two-year tests and snapshot dates need separate review.

Order of work

What should a company do first about ESG reporting?

Settle the entity, then the listing, then the size tests, then the dates, then where each report goes.

For the software categories that support these reporting workflows, see the ESG software guide.

More: ESG frameworks compared · carbon reporting software · ESG software compared · ESG standards

  1. 1

    Fix the entity and group boundary

    Which company, LLP or group is reporting, for which period.

  2. 2

    Confirm the listing category

    UKLR 6, 14, 15, 16 or 22, AIM, or none: it decides UK SRS and SECR’s quoted route.

  3. 3

    Run the size tests over two years

    Each regime’s own test, including any that looks back over two consecutive years.

  4. 4

    Diarise the snapshot dates

    5 April for gender pay gap, 31 December 2026 for ESOS Phase 4, the financial year for SECR.

  5. 5

    Map where each report goes

    Directors’ report, strategic report, annual financial report, website or regulator.

Sch 7 ¶20B · PS26/19 ¶3.6 · SI 2017/172 reg 1(2)

Preparation

How do you prepare each report?

Scope and period first, then each disclosure area, then the statements.

The reporting output

Annual financial report: UK SRS disclosures, explanations and applicable FCA statements.

  1. Step 101

    Scope and period

    Confirm the listing category, reporting entity, period and any transitional reliefs.

    UK SRS S1; FCA PS26/19 ↗

  2. Step 202

    Governance

    Describe oversight, responsibilities, skills and management’s role.

    UK SRS S1; FCA PS26/19 ↗

  3. Step 303

    Strategy

    Connect risks and opportunities to the business model, plans and financial effects.

    UK SRS S1; FCA PS26/19 ↗

  4. Step 404

    Risk management

    Explain identification, assessment, prioritisation, monitoring and integration.

    UK SRS S1; FCA PS26/19 ↗

  5. Step 505

    Metrics and targets

    Build the required metrics, target information and calculation evidence.

    UK SRS S1; FCA PS26/19 ↗

  6. Step 606

    Gaps and statements

    Record required explanations, relief reliance, locations, transition-plan and assurance statements as applicable.

    UK SRS S1; FCA PS26/19 ↗

Preparation order is suggested.

The legal requirement is in the cited instrument; scope and any exceptions need separate assessment.

For the FCA statements, read PS26/19 Appendix 1.

UK ESG reporting is a set of separate legal duties, so the work is to find the ones that reach you and report each where its own law says.

  1. 1 January 2027

    UK SRS applies to five listing categories, on comply or explain

    For accounting periods starting on or after this date.
  2. Exceed two of £36m, £18m and 250

    SECR reaches an unquoted company or LLP past that line

    Quoted companies are in at any size.
  3. 5 December 2027

    ESOS Phase 4 compliance is due

    After a qualification date of 31 December 2026.
  4. £36m turnover

    The modern slavery statement applies from this turnover

    Counting subsidiaries.
  5. 250 employees on 5 April

    Gender pay gap reporting applies from this headcount

    Also a route into ESOS.

Does ESG reporting have to be assured?

No UK statute requires it; listed companies say whether they obtained it.

Only an EU subsidiary in CSRD scope must carry an opinion.

RegimeAssurance required?What is stated
SECR and climate disclosureNoThe auditor reports on consistency with the accounts and compliance with the law, not on the figures
UK SRS, listed companiesNoWhether assurance was obtained and, if so, the provider, scope, level and standards (UKLR 6.6.6R(8)(d))
CSRD, an EU subsidiary in scopeYesA limited assurance opinion on the sustainability statement
Who must assureExplore

Who must assure

SECR and climate disclosure

No assurance required; the auditor reports on consistency with the accounts and compliance with the law.

Will UK ESG reporting rules change in 2027?

Not yet: two consultations close in October and November 2026, and none is law.

  1. 28 October 2026 · proposal

    FCA draft guidance TN 803.1 on comply or explain

    Comments close (Primary Market Bulletin 66).
  2. 30 November 2026 · proposal

    Modernising corporate reporting

    Would remove the directors’ report and move SECR into the first half of the annual report (MCR consultation, ¶149).
  3. No date · under consideration

    The s.414CB(2A) climate obligations alongside UK SRS

    Government is considering their future (Government response, Chapter 3).
  4. Before 6 April 2027 · statutory review

    First review of the 2022 climate regulations

  5. 29 June 2028 · made law

    ESG ratings providers need FCA authorisation

  6. 31 December 2030 · made law

    ESOS Phase 5 qualification; compliance by 5 December 2031

The FCA’s earlier proposals are in CP26/5; the final position is PS26/19.

Frequently asked

What else do people ask about ESG reporting in the UK?

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.

Which ESG thresholds are most often misquoted?

SECR’s two-of-three test most of all.

Which test does each duty use?

All monetary figures are sterling.
RegimeTestOperatorProvision
UK SRS (FCA)Listing category: UKLR 6, 14, 15, 16 or 22No size limb at allPS26/19 ¶3.6
SECR, unquoted companyExempt if two or more of: turnover not more than £36m; balance sheet not more than £18m; not more than 250 employees“Not more than”, two of threeSch 7 ¶20B(2)
Climate disclosureA traded company, bank, insurer, insurance market participant, AIM company or a company with turnover over £500m, which also has more than 500 employees“More than”; the headcount floor applies to every limbCA 2006 s.414CA
ESOSAt least 250 employees, or turnover in excess of £44m and balance sheet in excess of £38m“At least” OR two “in excess of” limbs joined by ANDSI 2014/1643 Sch 1
Modern slavery statementTotal turnover, including subsidiaries, of not less than £36m“Not less than”, one limbSI 2015/1833 regs 2–3
Gender pay gap250 or more employees on the 5 April snapshot dateA headcount on one day, not an averageSI 2017/172 reg 1(2)
Section 172(1) statementRequired unless the company qualifies as medium-sized: two or more of not more than £54m, £27m and 250An exemption, as SECR’s isCA 2006 s.465(3)

Why the £36 million figure appears twice

SECR’s £36 million and the Modern Slavery Act’s £36 million are a coincidence of drafting, not a cross-reference.

SECR is two of three conditions for one company; the slavery threshold is a single turnover test that counts subsidiaries.

What people most often get wrong

Spotted an error on this page? Write to hello@uksrs.org.uk.
Often saidWhat the primary source says
UK SRS S2 becomes mandatory for listed companies in 2027The final rules put all of UK SRS on comply or explain (PS26/19 ¶¶1.2, 1.7). The comply-or-explain reporting obligation continues when transitional reliefs expire.
UK SRS remains voluntary while regulators plan future mandatory integrationSince PS26/19 on 30 September 2026, listed companies in UKLR 6, 14, 15, 16 and 22 report against UK SRS or explain why not, for periods beginning on or after 1 January 2027.
SECR applies above 250 employees, £36m turnover or £18m balance sheetAn unquoted company or LLP is in scope only when it exceeds two of the three (Sch 7 ¶20B; SI 2008/1911 reg 12B).
515 companies must comply with UK SRSPS26/19 gives no total. CP26/5 estimated that around 600 listed companies would be affected; that was the consultation’s estimate.
Listed companies must publish a transition planThe FCA says it is not requiring one. Companies say whether they have published a plan and where it is.
Companies are premium-listed or standard-listedThose segments were abolished on 29 July 2024 and replaced by UK Listing Rules categories.

Back to the UK SRS reference.

Sources

Where does each figure come from?

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 62 sources fromFinancial Conduct AuthorityFCA HandbookDepartment for Business and Tradelegislation.gov.ukDepartment for Energy Security and Net ZeroEnvironment Agency
  1. Financial Conduct Authority
    Primary Market Bulletin 66: preparing for UK SRS

    Suggested preparation steps and the separate consultation on draft guidance.

  2. Financial Conduct Authority
    PS26/19: Aligning listed issuers' sustainability disclosures with international standards

    Published 30 September 2026: comply or explain across UK SRS for five listing categories.

  3. Financial Conduct Authority
    PS26/19 (PDF), ¶¶1.2, 1.7, 1.10, 3.6–3.24, 4.35 and Appendix 1

    The scope, dates, reliefs, early adopters and the made rule text, UKLR 6.6.6R(7A), (7B) and (8).

  4. Financial Conduct Authority
    CP26/5 (PDF), Annex 2 ¶43

    The consultation that PS26/19 finalises, and its estimate of around 600 affected companies.

  5. FCA Handbook
    UK Listing Rules sourcebook, UKLR 6.6

    The TCFD statement that governs periods beginning before 1 January 2027.

  6. Department for Business and Trade
    UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2

    Published 25 February 2026, available for voluntary use.

  7. Department for Business and Trade
    UK SRS S1 General Requirements (PDF)

    The four pillars, connected information, judgements and measurement uncertainty.

  8. Department for Business and Trade
    Government response on UK SRS, Chapter 3

    UK SRS S2 confirmed as a national reporting framework for section 414CB(6).

  9. legislation.gov.uk
    SI 2008/410 Schedule 7, Parts 7 and 7A

    SECR for quoted companies (Part 7) and large unquoted companies (Part 7A).

  10. legislation.gov.uk
    SI 2008/410 Schedule 7 paragraphs 20B and 20D

    The “not more than” exemption test and the conditional 40,000 kWh relief.

  11. legislation.gov.uk
    The Companies (Directors’ Report) and LLP (Energy and Carbon Report) Regulations 2018 (SI 2018/1155)

    The instrument that inserted SECR, for financial years beginning on or after 1 April 2019.

  12. Department for Energy Security and Net Zero
    SECR regulations: evaluation (29 January 2026)

    The measured population of about 19,900 organisations in scope.

  13. Department for Energy Security and Net Zero
    2026 post-implementation review of the SECR Regulations 2018

    The 11,300 forecast, the £7,100 mean ongoing cost and the recommendation to retain SECR with amendments.

  14. legislation.gov.uk
    Companies Act 2006, sections 414CA and 414CB

    The climate-related financial disclosure scope and the eight disclosures at s.414CB(2A).

  15. legislation.gov.uk
    The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 (SI 2022/31)

    The amending instrument, in force 6 April 2022, with its review duty in regulation 5(2).

  16. legislation.gov.uk
    The Limited Liability Partnerships (Climate-related Financial Disclosure) Regulations 2022 (SI 2022/46)

    The separate LLP instrument.

  17. legislation.gov.uk
    The Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021 (SI 2021/839)

    The trustee regime, its asset thresholds and its mandatory publication penalty.

  18. legislation.gov.uk
    The Energy Savings Opportunity Scheme Regulations 2014 (SI 2014/1643), Schedule 1

    The large-undertaking test: at least 250 employees, or both money limbs exceeded.

  19. legislation.gov.uk
    The Energy Savings Opportunity Scheme (Amendment) Regulations 2026 (SI 2026/701)

    The Phase 4 changes in force from 22 July 2026.

  20. legislation.gov.uk
    SI 2014/1643, Part 8 — civil penalties

    The penalty maxima for the ESOS offences.

  21. Environment Agency
    How to comply with ESOS Phase 4

    The qualification date, the compliance date and the 95% coverage rule.

  22. Environment Agency
    Enforcement and sanctions policy, Annex 2 (climate change schemes)

    The lower initial penalty the regulator normally imposes on new entrants.

  23. legislation.gov.uk
    Modern Slavery Act 2015, section 54, and SI 2015/1833

    The statement duty; the £36 million threshold sits in the regulations, not the Act.

  24. legislation.gov.uk
    The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 (SI 2017/172)

    The 250-employee snapshot test and the six figures.

  25. legislation.gov.uk
    Companies Act 2006, section 414CZA

    The section 172(1) statement and its medium-sized exemption.

  26. Financial Reporting Council
    UK Corporate Governance Code 2024

    Provision 29 and the Code’s scope by listing category.

  27. Financial Conduct Authority
    Sustainability Disclosure Requirements (SDR) regime

    The four investment labels and the anti-greenwashing rule for all authorised firms.

  28. legislation.gov.uk
    The FSMA 2000 (Regulated Activities) (ESG Ratings) Order 2025 (SI 2025/1349)

    Made 15 December 2025; authorisation required from 29 June 2028.

  29. Cabinet Office
    PPN 006: taking account of carbon reduction plans in the procurement of major government contracts

    A carbon reduction plan for contracts above £5 million a year, including VAT.

  30. legislation.gov.uk
    The Greenhouse Gas Emissions Trading Scheme Order 2020 (SI 2020/1265)

    Monitoring, verified reports by 31 March, surrender by 30 April, and the excess emissions penalty in article 52.

  31. legislation.gov.uk
    Finance Act 2026, Part 5 (Carbon Border Adjustment Mechanism)

    The UK CBAM: a tax on imports of CBAM goods from 1 January 2027, with registration from 1 January 2028.

  32. legislation.gov.uk
    The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332)

    The large and small producer tests and the packaging data each producer reports.

  33. Department for Business, Innovation, Science and Trade
    Modernising corporate reporting — consultation document

    Open until 30 November 2026; paragraph 149 on where SECR disclosures would sit.

  34. EUR-Lex
    Directive (EU) 2026/470 (Omnibus I)

    The narrowed CSRD scope, the value chain cap and the 19 March 2027 transposition date.

  35. EUR-Lex
    Delegated Regulations (EU) 2026/1560 and 2026/1563

    The voluntary standard that sets the cap, and the revised ESRS, both applying to financial years from 2027.

  36. European Commission
    Additional explanatory information regarding the value chain cap (6 May 2026)

    The customer must say which requested items exceed the cap and that the supplier may decline them.

  37. Financial Conduct Authority
    UK Listing Rules sourcebook (UKLR)
  38. Department for Business and Trade
    UK SRS S2 Climate-related Disclosures (PDF)
  39. legislation.gov.uk
    SI 2008/410 Schedule 7, Part 7
  40. legislation.gov.uk
    SI 2008/410 Schedule 7, paragraph 20D
  41. legislation.gov.uk
    SI 2018/1155, Part 3
  42. Department for Energy Security and Net Zero
    SECR evaluation report (PDF)
  43. Department for Energy Security and Net Zero
    SECR post-implementation review (PDF)
  44. Department for Energy Security and Net Zero
    Call for evidence on Scope 3 emissions reporting (October 2023)
  45. DESNZ and Defra
    Environmental Reporting Guidelines, including SECR guidance
  46. Department for Energy Security and Net Zero
    Government conversion factors for company reporting
  47. GHG Protocol
    Scope 2 Guidance
  48. legislation.gov.uk
    SI 2022/733
  49. GOV.UK
    Energy Savings Opportunity Scheme (ESOS)
  50. legislation.gov.uk
    SI 2014/1643, regulation 10
  51. legislation.gov.uk
    SI 2026/701, regulation 29
  52. legislation.gov.uk
    SI 2026/701, explanatory memorandum (PDF)
  53. Financial Reporting Council
    Sustainability reporting developments: frequently asked questions
  54. Council of the European Union
    Council signs off simplification of sustainability reporting (24 February 2026)
  55. EUR-Lex
    Delegated Regulation (EU) 2026/1563 (revised ESRS)
  56. EFRAG
    EFRAG
  57. legislation.gov.uk
    Companies Act 2006, section 465
  58. legislation.gov.uk
    SI 2024/1303
  59. legislation.gov.uk
    Companies Act 2006, section 456

    Court-ordered revision of a defective strategic or directors’ report.

  60. legislation.gov.uk
    SI 2021/465, article 4

    The FRC is authorised for the purposes of section 456 from 6 May 2021.

  61. legislation.gov.uk
    Companies Act 2006, section 419

    The directors’ offence of approving a non-compliant directors’ report.

  62. legislation.gov.uk
    Companies Act 2006, section 414D

    Approval of the strategic report, and the directors’ offence for a non-compliant one.

Where are the related questions answered?

Each neighbouring question has its own guide.

QuestionWhere it is answered
Social value in procurementThe social value model
Membership bodiesSustainability reporting for membership organisations
Supply-chain due diligenceUK deforestation due diligence
Investment stewardshipThe UK Stewardship Code
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See also: MEES · EUDR · Green Claims Code.

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