The UK prescribes no ESG report template — it prescribes rows

The government publishes a template — and buries it on page 50

This is the single most useful fact on the page, and almost nobody writing about UK ESG templates mentions it.

In March 2019 the then Department for Business, Energy and Industrial Strategy published the Environmental Reporting Guidelines, including streamlined energy and carbon reporting guidance.

Under the heading “Reporting format”, on page 48, it says: “There is no prescribed proforma for reporting — organisations could develop their own format to fit their business.”

Two sentences later, it says: “To assist organisations, we have included a reporting template that organisations are strongly encouraged to use to facilitate consistency of disclosed information.”

Both statements are true at once, and the tension between them is the reason this subject is confusing.

What follows in that document is two complete worked tables.

One begins on page 50, for quoted companies; the other on page 54, for large unquoted companies and large LLPs.

Every single row in both is tagged either [mandatory] or [optional] — which means the government has already done the hardest part of the job, and then filed it where nobody looks.

Both tables are reproduced in full further down this page, ungated.

Eight rows of thirty-two are compulsory — the rest is marked optional

Count the rows in the published template for large unquoted companies and LLPs, and the shape of the obligation becomes obvious.

Eight are tagged [mandatory].

The remaining twenty-four are tagged [optional] — a long tail of Scope 3 categories, market-based Scope 2, offsets, domestic carbon units, net figures and third-party verification.

For a quoted company the ratio is six compulsory rows against twenty-three optional.

This is not an argument for reporting the minimum.

The guidelines are explicit that organisations are “encouraged to go wider than the minimum legal requirements”, and there are good reasons to — investors, lenders and customers all read further than the statutory floor.

But knowing where the floor is changes how you plan a first year, and a template that does not distinguish the two is actively unhelpful.

The evaluation evidence suggests the disclosure itself is doing work.

DESNZ's January 2026 evaluation puts SECR's net present social value at £5,100m with a benefit–cost ratio of 2.72, and found that for 79% of complying businesses the regulations led to additional data entering the public domain [2].

Only 18% said all the required data would have been published anyway.

Compulsory, strongly encouraged, or voluntary

The legend below is used consistently for every row in every table on this page, including the swarm's own colours.

Keep the three separate in your own document and you solve most of the problem the government's evaluators identified.

A reader who cannot tell which of your figures you were obliged to publish cannot tell what your disclosure means.

One figure, two regimes, two different duties

A single number can sit in two documents under two different obligations, and that is the practical reason template design matters.

Your Scope 1 and Scope 2 emissions are a compulsory SECR row today.

The same figures would be part of a UK SRS S2 climate disclosure — which is voluntary today and proposed as mandatory for certain listed categories from 2027 [5].

Scope 3 is where the two diverge most sharply.

Under SECR only the grey-fleet line is compulsory, and only for large unquoted companies and LLPs; under UK SRS S2 the expectation is full Scope 3 disclosure, with the FCA proposing a one-year relief on it [5].

The government has said it will consider how UK SRS and SECR interact so as to reduce duplication, and has not yet said how [6].

Until it does, the sensible template design is one dataset with two views — collect once, present twice — rather than two parallel workbooks that drift apart by the second year.

ESOS prescribes its contents — and is not filed in your accounts

ESOS behaves differently from everything else on this page, and mixing it into an annual-report template is a category error.

The Energy Savings Opportunity Scheme runs in four-year phases, and Phase 4's compliance date is 5 December 2027, with the action plan due a year later on 5 December 2028 [7].

Its outputs are submitted through the MESOS portal and signed off by one or more directors — they do not appear in the directors' report at all [8].

What Phase 4 does prescribe is content.

The ESOS report and notification must state the energy savings actually achieved during the compliance period — a description of each measure implemented, the saving from each in kWh, and each measure's energy-saving category [9].

They must also identify proposed measures from the previous action plan that were not implemented, and explain why [10].

One point worth stating plainly, because it is widely got wrong: there is no penalty for failing to submit an action plan or a progress update [11].

The regulators have said they will not take enforcement action over non-submission — but the scheme administrator publishes the failure, which is its own kind of sanction.

DESNZ's evaluators were told the missing template causes real inconsistency

In January 2026 the Department for Energy Security and Net Zero published an evaluation of the SECR framework, carried out by ICF Consulting Services and IFF Research [2].

It is the closest thing there is to an official verdict on this question, and it says something quite specific.

Read the attribution carefully, because it matters.

This is what interviewees told the evaluators, recorded as a qualitative finding — it is not a departmental finding of fact, and this page does not present it as one.

The recommendation that follows is the interesting half.

“The existing reporting template.”

The evaluators are not asking for a template to be written — they are asking for people to be pointed at the one published in 2019, which the report cites directly.

Elsewhere the same evaluation records that stakeholders saw value in “providing prescribed templates for SECR reporting to increase consistency of SECR disclosures across organisations and over time”, and lists standardised reporting templates among the suggested future improvements [2].

It also records the underlying complaint in plainer language: that SECR reporting “can often be lost within annual reports due to a lack of consistency in their placement”.

So the position, as of the government's own most recent look at it, is this.

This page is, in the most literal sense available, that signposting.

The intensity ratio is compulsory — and the guidelines will not tell you which one

Of the eight compulsory rows, the intensity ratio causes more difficulty than the other seven together.

The requirement is that you disclose at least one ratio which expresses your annual emissions in relation to a quantifiable factor associated with your activities.

The published template gives the example of tonnes of CO₂e per £100,000 revenue — and the words “e.g.” in that row are doing a great deal of work [1].

Revenue is the most common choice because it is always available and always comparable to your own prior year.

It is also the choice most sensitive to inflation and to a change in business mix, which is why many organisations disclose a second, physical ratio alongside it — per square metre, per tonne produced, per full-time equivalent employee.

A second ratio is optional, and it is one of the optional rows most worth adding.

The evaluation found that fewer than half of complying businesses — 43% — said the regulations had changed their use of intensity metrics at all [2].

Whatever you choose, the template's own logic is that the ratio must be built from the mandatory fields above it, so that a reader can reconstruct it.

Methodology is the one compulsory row that is prose, not a number

Every compulsory row in both published tables is a figure, except this one.

The methodology row asks you to state the methodology you used to calculate the disclosed figures.

In practice that is a short paragraph naming three things: the standard you followed, the emission factors you applied, and the consolidation approach you took.

For most UK reporters the standard is the GHG Protocol Corporate Standard and the factors are the UK Government greenhouse gas conversion factors published each year by DESNZ [14].

The consolidation approach — operational control, financial control or equity share — determines which emissions are yours at all, and is the thing most methodology statements omit.

State the year of the conversion factors you used, not just the publisher.

Factors are restated annually and a disclosure that does not name its factor year cannot be compared with its own prior year, which defeats the point of the comparison column.

The energy efficiency narrative is part of the disclosure

Alongside the table, SECR requires a description of the principal measures taken to improve energy efficiency in the period.

The guidelines model this with a worked example narrative, and the striking thing about it is its brevity — a few sentences naming the measures, the expected saving, and where the recommendations came from.

Two things in that example are worth copying.

It quantifies the expected saving in kWh rather than describing the measures qualitatively.

And it connects the narrative to the ESOS audit, which is the single cheapest way to make two separate compliance exercises reinforce each other rather than duplicate.

If your organisation is in scope of both, your ESOS recommendations are the natural source for this paragraph, and Phase 4's new achieved-savings reporting will give you the measured figures to put in it [9].

Build the dataset once, then present it twice

The order below is the one the structure of the regulations implies, and it is the order that avoids the most rework.

If you are also adopting UK SRS voluntarily, the same dataset feeds the metrics-and-targets pillar without recollection.

That is the whole argument for one dataset and two views.