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.

UK green finance · the regulatory stack

Green finance in the UK: the 2026 regulatory guide

Green finance in the UK is a market — green gilts, green bonds and loans, sustainability-linked lending, labelled funds — wrapped in a growing set of rules.

The 2023 green finance strategy sets the policy; the FCA’s product labels and anti-greenwashing rule govern what is sold; and from 2027 listed companies report against UK SRS or explain.

The UK chose not to build a green taxonomy, and providing an ESG rating becomes regulated only in June 2028.

Definitions

What green finance means in the UK

Green finance is lending, investment and insurance that supports environmentally sustainable activity.

It includes use-of-proceeds instruments, where the money goes to specified green projects — green bonds, green loans and the UK’s green gilts.

It includes performance-linked instruments, where the money is general-purpose but the terms move with sustainability targets — sustainability-linked loans and bonds.

And it includes investment products marketed on their sustainability characteristics, which in the UK sit under the FCA’s Sustainability Disclosure Requirements.

Around the market sits a disclosure-led regulatory wrapper: what funds may call themselves, what listed companies must report, how banks manage climate risk, and soon how ESG ratings are produced.

The UK’s distinctive choice is to regulate disclosure and claims rather than define green activity in law: HM Treasury decided on 15 July 2025 not to proceed with a UK taxonomy, as set out on our green taxonomy page.

Many sustainability consultancies advise on green finance frameworks and disclosure; the rules themselves are set out below, at the source.

Policy and the sovereign

The 2023 strategy and the green gilts

The government’s green finance strategy was first published in July 2019 and replaced on 30 March 2023 by “Mobilising green investment: 2023 green finance strategy”.

It sets out a framework for the UK to become the world’s first Net Zero Aligned Financial Centre, and plans for the information and tools market participants need to align with climate and nature goals.

It is policy: it explains what the government intends, and the binding parts arrive through other instruments.

The sovereign’s own contribution is the green gilt programme, run by the UK Debt Management Office.

The UK Government Green Financing Framework, first published on 30 June 2021 and updated on 26 November 2025, sets which government expenditures green gilts and the retail Green Savings Bonds may finance.

It was developed in line with the ICMA Green Bond Principles.

The first green gilt raised £10 billion on 21 September 2021: a 12-year bond maturing on 31 July 2033, financing categories including clean transport, energy efficiency and renewable energy.

A second green gilt, a new 32-year maturity, followed on 21 October 2021, building out a green yield curve.

  1. 2 Jul 2019
    First strategy

    Green finance strategy published.

  2. 30 Jun 2021
    Green Financing Framework

    Published by HM Treasury.

  3. 21 Sep 2021
    First green gilt

    £10bn, 12-year, maturing 31 July 2033.

  4. 21 Oct 2021
    Second green gilt

    A new 32-year maturity.

  5. 30 Mar 2023
    2023 strategy

    “Mobilising green investment”.

  6. 26 Nov 2025
    Framework updated

    Green Financing Framework revised.

The market

Green bonds, loans and sustainability-linked debt

Two models run through the market: money for specified green projects, and money for anything on terms that move with sustainability targets.

Both rest on voluntary market principles, not statute.

Sources: ICMA Green Bond Principles, June 2025 · UK Government Green Financing Framework · FCA ESG 4
InstrumentWhere the money goesWhat moves the termsStandard behind it
Green bondEligible green projects (use of proceeds)Standard bond pricingICMA Green Bond Principles
UK green giltEligible government green expenditureSovereign pricingUK Government Green Financing Framework
Green loanEligible green projects (use of proceeds)Standard loan pricingMarket loan principles
Sustainability-linked loanGeneral corporate purposesMargin tied to sustainability performance targetsMarket loan principles
Sustainability-linked bondGeneral corporate purposesBond characteristics tied to whether targets are metICMA Sustainability-Linked Bond Principles
Labelled fundAssets in line with a sustainability objectiven/aFCA SDR labels (rules)

The Green Bond Principles describe themselves as “voluntary process guidelines” and set four core components: use of proceeds, the process for project evaluation and selection, management of proceeds, and reporting.

They recommend a green bond framework and external review before issuance, and annual reporting on allocation until the proceeds are fully allocated.

Labels in the debt markets are market conventions, not UK law: no UK statute defines a green bond.

What UK law does reach is the claim made about a product to a UK client, through the FCA’s anti-greenwashing rule.

FCA SDR

Labels, names and the anti-greenwashing rule

The FCA’s Sustainability Disclosure Requirements, made in PS23/16, have four parts.

The anti-greenwashing rule, ESG 4.3.1R, was made on 28 November 2023 and applies from 31 May 2024 to every FCA-authorised firm.

It requires any reference to the sustainability characteristics of a product or service to be consistent with those characteristics and fair, clear and not misleading.

It reaches products and services, not claims a firm makes about itself, which the FCA’s guidance FG24/3 points to the Principles, the Consumer Duty and the CMA and ASA.

The four investment labels — Sustainability Focus, Improvers, Impact and Mixed Goals — are drafted as a prohibition in ESG 4.1.1R, with a carve-out letting qualifying managers use one from 31 July 2024.

A labelled product must invest at least 70% of its gross assets in line with its sustainability objective, against a robust, evidence-based standard (ESG 4.2.4R).

The naming and marketing rules restrict thirteen terms in a retail product’s name or financial promotion, with a longstop of 2 December 2024.

An unlabelled product may still use ten of them, but never “sustainable”, “sustainability” or “impact”; and a Focus, Improvers or Mixed Goals product may not use “impact” in its name.

The checker beside this text applies those naming rules to a name you type.

The entity-level report is the fixed calendar duty — 2 December 2025 for enhanced SM&CR managers and 2 December 2026 for others with £5 billion or more under management — while the product-level report runs from first use of a label or restricted term.

Linklaters’ quick guide is one law firm’s summary; the full rules are on our FCA SDR and anti-greenwashing page.

FCA SDR · fund name check

Type a product name

The check looks for the thirteen terms the FCA restricts in a retail product’s name. It applies to managers of in-scope funds marketed to retail clients.

Rules: FCA Handbook ESG 4.1.1R, 4.2.4R, 4.3.1R, 4.3.2R(2), 4.3.4R(2) and 4.3.5R.

A screen of the words only; the catch-all term and the label criteria need judgement.

Nothing you type leaves your browser.

Listed companies

UK SRS: the disclosure half of the stack

Companies raising capital on UK markets meet green finance through disclosure.

The UK SRS S1 and S2 were published by the Department for Business and Trade on 25 February 2026 for voluntary use.

The FCA’s final rules, PS26/19 of 30 September 2026, require listed companies in UKLR 6, 14, 15, 16 and 22 to report against them on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reports in 2028.

They finalise CP26/5, which had proposed a mandatory S2; the final rules put all of UK SRS on comply or explain, with a one-year Scope 3 relief and a two-year relief for S1 matters beyond climate.

The new rules replace the TCFD-aligned listing-rule disclosures.

A listed company in UKLR 6, 16 or 22 also says whether it has published a climate transition plan and where — there is no duty to have one; see UK SRS transition plan disclosures.

Where the report was assured, it names the provider, the disclosures covered and the standard used; assurance itself is not required.

The listed-company position in full is on the FCA’s UK SRS rules, and the standards on UK SRS S1 and S2.

Banks, insurers and asset managers

Financed emissions, PCAF and the PRA

For financial institutions the largest emissions are usually those of the companies they lend to, insure and invest in — financed emissions, part of Scope 3 category 15.

UK SRS S2 paragraph 29(a)(vi)(2) asks for additional information about financed emissions where an entity’s activities include asset management, commercial banking or insurance, with application guidance at paragraphs B59 to B63A.

For asset management, B61 asks for absolute gross financed emissions by scope, the assets covered and the share of the total, and the methodology used — without prescribing one.

The UK added one duty the ISSB text does not have: where an entity cannot reliably estimate financed emissions for the same period as its accounts, B59A requires it to say why, how it estimated what it reports, and its plan with a timeline.

The method most used is the PCAF standard, published in three parts: financed emissions, facilitated emissions and insurance-associated emissions.

It is named in no UK instrument, and its data-quality scale runs the opposite way to CDP’s scores: 1 is the best, 5 the worst.

PCAF itself says its later additions have not been reviewed by the GHG Protocol, whose review service has closed; the GHG Protocol’s own standards are covered on the GHG Protocol.

The category 15 detail is on UK SRS Scope 3 reporting, and the ISSB’s December 2025 amendments on IFRS S2.

For banks and insurers the prudential expectation is the PRA’s SS5/25, which replaced SS3/19 in its entirety on 3 December 2025 and covers governance, risk management, climate scenario analysis, data and disclosures.

A supervisory statement sets expectations, not rules.

Asset managers and asset owners in the FCA’s scope keep their entity-level TCFD report, but the product-level TCFD metrics rule was removed on 25 September 2026; clients can still request Scope 1, 2 and 3 data for a product.

Our sister site covers financed emissions reporting and the PCAF standard in the UK in depth.

ESG ratings

ESG ratings: made law, not yet biting

The FSMA 2000 (Regulated Activities) (ESG Ratings) Order 2025, SI 2025/1349, was made on 15 December 2025.

Providing an ESG rating becomes a regulated activity on 29 June 2028; until then its substantive provisions are in force only for the FCA’s rule-making.

Needing authorisation is the consequence of that, not the Order’s own words.

The FCA consulted in CP25/34, which closed on 31 March 2026, and plans to publish final rules in a Q4 2026 policy statement.

Today the ratings that investors and lenders use are unregulated private opinions in the UK.

The EU’s regime is already live: Regulation (EU) 2024/3005 has applied since 2 July 2026, existing providers had to notify ESMA by 2 August 2026, and they must apply for authorisation by 2 November 2026.

The two are not parallel: the EU’s is a standalone regulation supervised by ESMA directly, the UK’s works through the FCA’s FSMA perimeter, and they bite two years apart.

Paul Hastings’ client alert summarised the UK Order when it was made.

The whole stack

Every instrument, by status

Filter to see what is law today, what is made but not yet applying, and what is a market standard or policy.

Show

Showing 15 of 15

InstrumentWhat it does, and from whenOwner
2023 green finance strategyGovernment policy framework; published 30 March 2023HM Government
Green giltsSovereign green bonds under the Green Financing Framework; first issued 21 September 2021HM Treasury / DMO
Green bonds and loansUse of proceeds for eligible green projects; ICMA Green Bond Principles, four core componentsICMA (voluntary)
Sustainability-linked loans and bondsTerms tied to sustainability performance targets; general-purpose proceedsMarket principles (voluntary)
Anti-greenwashing rule (ESG 4.3.1R)All FCA-authorised firms; applies from 31 May 2024FCA
SDR investment labels (ESG 4.1.1R)Prohibition with a carve-out for qualifying managers from 31 July 2024FCA
SDR naming and marketing (ESG 4.3.2R)Thirteen restricted terms for retail products; longstop 2 December 2024FCA
SDR entity-level report (ESG 5.4.3R(2))2 December 2025 (enhanced SM&CR managers); 2 December 2026 (others with £5bn or more under management)FCA
TCFD entity report for asset managers and owners (ESG 2.2.1R)Continues; product-level TCFD metrics removed on 25 September 2026FCA
UK SRS for listed companies (PS26/19)Comply or explain for accounting periods beginning on or after 1 January 2027FCA
ESG ratings (SI 2025/1349)Regulated activity from 29 June 2028; FCA rules due Q4 2026HM Treasury / FCA
PRA SS5/25Climate risk expectations for banks and insurers, from 3 December 2025PRA
PCAF standardFinanced-emissions method; named in no UK instrumentPCAF
UK Green TaxonomyWork “should not proceed”, 15 July 2025HM Treasury
EU ESG Ratings Regulation (2024/3005)Applies from 2 July 2026; ESMA authorisationEU

Each row is sourced in the sections above.

Nothing you choose is stored or sent.

The FCA’s climate change and sustainable finance hub collects its own material; note that it cites the anti-greenwashing guidance as FG24/2, which is mortgage guidance — the correct reference is FG24/3.

The Treasury’s taxonomy decision named UK SRS, assurance and transition plans as its priorities; Macfarlanes’ note on the decision summarises it from the market’s side.

What comes next

Green finance dates still ahead

Three moves dominate the next two years.

First, listed companies prepare their first UK SRS reports, for accounting periods beginning on or after 1 January 2027.

Second, the FCA finalises its ESG ratings rules, with the regime biting on 29 June 2028.

Third, the remaining SDR entity-level reports fall due on 2 December 2026.

None of these creates a UK green taxonomy, and none requires a company to have a transition plan.

If you are a lender or investor

The data you ask companies for is shaped by what they must report.

From 2027, listed borrowers and investees report against UK SRS or explain — so ask for their UK SRS disclosures, not a bespoke questionnaire, where they exist.

For a specific institution’s position, book a free 15-minute call.

  1. 2 Nov 2026
    EU ratings authorisation

    Existing providers apply to ESMA.

  2. Q4 2026
    FCA ESG ratings rules

    Policy statement planned after CP25/34.

  3. 2 Dec 2026
    SDR entity reports

    Managers with £5bn or more under management, not enhanced SM&CR.

  4. FY2027
    UK SRS comply or explain

    Listed companies, first reports in 2028.

  5. 29 Jun 2028
    ESG ratings regulated

    Providing an ESG rating becomes a regulated activity.

Frequently asked

Questions people ask

What is green finance?

Green finance is lending, investment and insurance that supports environmentally sustainable activity: green bonds and loans, sustainability-linked loans and bonds, sovereign green gilts, and funds with sustainability objectives.

In the UK it also means the rules around it: the FCA’s product labels and anti-greenwashing rule, listed-company disclosure against UK SRS, and the coming regulation of ESG ratings.

What is the UK Green Finance Strategy?

The government’s policy framework for green finance.

The first strategy was published in July 2019; the current one, “Mobilising green investment: 2023 green finance strategy”, was published on 30 March 2023 and sets out a framework for the UK to become the world’s first Net Zero Aligned Financial Centre. It is policy, not law.

What are UK green gilts?

Sovereign bonds whose proceeds are allocated to eligible green government spending under the UK Government Green Financing Framework, first published on 30 June 2021 and updated on 26 November 2025.

The first green gilt, a 12-year bond maturing on 31 July 2033, raised £10 billion on 21 September 2021; a second, 32-year green gilt followed on 21 October 2021.

Is there a UK Green Taxonomy?

No. HM Treasury decided on 15 July 2025 that work on a UK Taxonomy should not proceed, naming UK SRS, assurance of sustainability reporting and transition plans as its priorities instead.

The EU Taxonomy still reaches UK groups through EU entities and EU finance.

What is the FCA SDR?

The FCA’s Sustainability Disclosure Requirements: four voluntary investment labels for qualifying funds from 31 July 2024, naming and marketing rules restricting thirteen terms for retail products, product and entity-level disclosures, and the anti-greenwashing rule.

The anti-greenwashing rule applies to every FCA-authorised firm from 31 May 2024.

What is the anti-greenwashing rule?

ESG 4.3.1R.

Made on 28 November 2023 and applying from 31 May 2024, it requires any reference to the sustainability characteristics of a product or service to be consistent with those characteristics and fair, clear and not misleading.

It binds all FCA-authorised firms, for products and services; claims a firm makes about itself fall under other rules and the CMA and ASA.

The FCA’s guidance on it is FG24/3.

What is the UK ESG ratings regulation?

The FSMA 2000 (Regulated Activities) (ESG Ratings) Order 2025, SI 2025/1349, made on 15 December 2025.

Providing an ESG rating becomes a regulated activity on 29 June 2028; until then the provisions are in force only for FCA rule-making.

The FCA consulted in CP25/34, which closed on 31 March 2026, and plans final rules in Q4 2026.

What is PCAF and is it required in the UK?

PCAF is the Partnership for Carbon Accounting Financials, whose standard measures financed emissions — the emissions attributable to a financial institution’s loans and investments.

It is required nowhere in UK law: UK SRS S2 asks banks, asset managers and insurers for financed emissions and the method used, without naming PCAF.

PCAF’s data-quality scale runs from 1, the best, to 5.

What is a sustainability-linked loan?

A loan whose terms, typically the margin, move with whether the borrower meets agreed sustainability performance targets.

The proceeds can be used for general corporate purposes.

A green loan or green bond is different: its proceeds go to specific eligible green projects, the use-of-proceeds model in the ICMA Green Bond Principles.

What guides UK banks’ climate approach?

For risk management, the PRA’s Supervisory Statement SS5/25, which replaced SS3/19 in its entirety on 3 December 2025 and sets expectations on governance, risk management, scenario analysis, data and disclosures.

For disclosure, a listed bank reports against UK SRS on a comply-or-explain basis from 2027, including financed emissions under UK SRS S2.

What did the FCA publish in September 2026?

PS26/19, on 30 September 2026: final rules requiring listed companies in UKLR 6, 14, 15, 16 and 22 to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reports in 2028.

Separately, FCA 2026/59 removed the product-level TCFD metrics rule for asset managers on 25 September 2026.

Sources

Primary sources

Every figure, date and status on this page traces to the instrument’s owner.

Secondary commentary is never the source for a number.

Checked against 15 sources fromHM Government (GOV.UK)UK Debt Management OfficeHM Treasury (GOV.UK)HM TreasuryICMAFinancial Conduct Authority
  1. HM Government (GOV.UK)
    Mobilising green investment: 2023 green finance strategy

    Published 30 March 2023; the framework for a Net Zero Aligned Financial Centre.

  2. UK Debt Management Office
    Green gilts

    Green Financing Framework (30 June 2021, updated 26 November 2025) and the green gilt syndications.

  3. HM Treasury (GOV.UK)
    UK’s first Green Gilt raises £10 billion for green projects, 21 September 2021

    The inaugural 12-year green gilt, maturing 31 July 2033.

  4. HM Treasury
    UK Government Green Financing Framework (June 2021)

    Use of proceeds for green gilts and Green Savings Bonds; aligned with the ICMA Green Bond Principles.

  5. ICMA
    Green Bond Principles (June 2025)

    Voluntary process guidelines; four core components.

  6. Financial Conduct Authority
    FCA Handbook, ESG 4 — labels, naming and marketing, anti-greenwashing

    ESG 4.1.1R, 4.2.4R, 4.3.1R, 4.3.2R, 4.3.4R, 4.3.5R.

  7. Financial Conduct Authority
    PS23/16: Sustainability Disclosure Requirements and investment labels

    The SDR rules as made, including ESG 5.4.3R and ESG TP 1.

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

    Made 15 December 2025; providing an ESG rating becomes a regulated activity on 29 June 2028.

  9. Financial Conduct Authority
    CP25/34: ESG ratings — proposed approach to regulation

    Closed 31 March 2026; final rules planned in a Q4 2026 policy statement.

  10. EUR-Lex
    Regulation (EU) 2024/3005 on ESG rating activities

    Applies from 2 July 2026; supervised by ESMA.

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

    Comply or explain against UK SRS for listed companies from 2027.

  12. Department for Business and Trade
    UK SRS S2 — ¶29(a)(vi)(2), ¶¶B59–B61, B59A

    Financed emissions for asset management, commercial banking and insurance.

  13. PCAF
    The Global GHG Accounting and Reporting Standard for the Financial Industry

    Parts A, B and C; the data-quality scale runs 1 (best) to 5.

  14. Bank of England (PRA)
    SS5/25 — Enhancing banks’ and insurers’ approaches to managing climate-related risks

    Replaced SS3/19 in its entirety on 3 December 2025; expectations, not rules.

  15. HM Treasury (GOV.UK)
    UK Green Taxonomy: consultation response, 15 July 2025

    Work on a UK Taxonomy “should not proceed”.

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