Sustainability recruitment · senior roles · checked 1 October 2026
Chief sustainability officer: a title is not a position
“Chief” does not make someone a director, because the Companies Act looks to the position occupied, not the name.
The duties, the report approvals and the ESOS sign-off attach to directors or to people exercising management control, so the title alone settles nothing.
The test below shows what a post-holder can and cannot do on the facts, and the table maps each legal role to the person it names.
The test
What does the title carry?
Tick what is true of the post-holder.
The panel shows which legal roles follow, and which do not, on those facts.
Section 250 of the Companies Act 2006 defines “director” to include any person occupying the position of director, by whatever name called.
A chief sustainability officer on the board is therefore a director, and one who attends the board at its invitation is not.
A shadow director under section 251 is someone whose directions the directors are accustomed to follow, which a senior adviser is not merely by being listened to.
The consequence is practical: the general duties, including section 172, are owed by directors, and a title does not create them.
A company hiring a CSO should decide before the offer whether the post is a board appointment, because that decision changes the duties, the liability and the remit.
What does the title carry in law?
- Cannot, on these factsSection 172 and the other general duties of directors
The general duties are owed by directors. A title, however senior, does not create them; a person occupying the position of a director is one whatever the title.
- Cannot, on these factsSigning the directors’ report (which carries SECR)
The board approves it and a director or the company secretary signs on its behalf.
- Cannot, on these factsSigning the ESOS assessment as a responsible officer
A responsible officer is a director or a person exercising management control.
- CanPreparing the figures, the evidence file and the timetable
The law names no preparer, so anyone the company appoints can do this.
CA 2006 ss.250, 419(1), 172; SI 2014/1643 reg 30.
Whether someone “exercises management control” is a question of fact for each company.
Not legal advice.
Nothing you tick is stored or sent.
Who the law names
Each legal role, and the person it names
| Legal role | Who holds it | Provision |
|---|---|---|
| General duties (s.172 and others) | Directors | Companies Act 2006 |
| Approving the strategic and directors’ reports | The board | CA 2006 s.419; s.414CB for climate disclosures |
| Signing the directors’ report (carries SECR) | A director or the secretary | CA 2006 s.419 |
| Signing the ESOS assessment | Responsible officers: directors or people exercising management control | SI 2014/1643 reg 30 |
| Declaring on material controls | The board (Code Provision 29) | UK Corporate Governance Code 2024 |
| Preparing the figures, evidence and timetable | Anyone the company appoints | No provision names a title |
That table is the reason a board-level title is less informative than the remit behind it.
A CSO who is not a director owns the work and the evidence, as the head of sustainability guide sets out, and a CSO who is a director also holds the approvals.
The Code’s Provision 29 adds a board declaration on material controls that the 2024 Code extends to reporting, for financial years beginning on or after 1 January 2026.
Climate disclosures under section 414CB are a board responsibility too, so the CSO’s evidence file is the board’s evidence.
Governance and assurance
What the board still decides
For a listed company, the FCA’s final rules in PS26/19 are comply or explain, and the annual report states whether disclosures were assured.
That statement is the board’s, and the guides on UK SRS compliance, UK SRS S1 and UK SRS S1 and S2 set out what it says.
The CSO’s part is to make the board’s decisions easier, with evidence, and to say so in the remit.
Whether to obtain assurance, which no UK rule requires.
Whether to adopt a target, which no UK rule requires either.
See the sustainability assurance guide.
Pay evidence
What can be said about CSO pay
No official statistic reports pay for a chief sustainability officer.
The Home Office going rate for the nearest group, SOC 2152, is £37,200, and it covers every grade, as the ONS classification defines the group.
ISEP’s 2025 report found an average of £91,911 for Fellows and a gender pay gap of 14.7%, wider at senior level, among its respondents.
The Annual Survey of Hours and Earnings is the underlying source, and the salary guide shows how far to rely on each figure.
The sustainability director guide maps accountability up to the board, the ESG reporting manager guide works the reporting cycle, and the hub lists the rest.
Frequently asked
Chief sustainability officer, answered
What is a chief sustainability officer?
A senior executive title for the person who leads a company’s sustainability strategy.
It has no legal definition in the UK, so what the post carries depends on whether the post-holder is also a director and on what the company delegates.
Is a chief sustainability officer a director?
Not by virtue of the title.
Section 250 of the Companies Act 2006 says “director” includes any person occupying the position of a director, by whatever name called, so a CSO is a director only if they occupy that position, usually by sitting on the board.
What is a shadow director?
Under section 251, a person in accordance with whose directions or instructions the directors are accustomed to act.
A senior sustainability executive is not one merely because the board follows their advice; the test is accustomed direction and professional advice is excluded.
Who is legally responsible for sustainability reporting?
The company, through its directors.
The board approves the strategic and directors’ reports and a director or the company secretary signs the directors’ report under section 419.
A CSO who is not a director prepares and advises but does not hold the approval.
Can a CSO sign off ESOS?
Only as a responsible officer, which means a director or a person exercising management control.
A CSO who exercises management control over the company’s operations can qualify, and that is a question of fact.
What duties do directors have that a CSO may not?
The general duties in the Companies Act 2006, including section 172, the duty to promote the success of the company having regard to factors including the impact of the company’s operations on the community and the environment.
They are owed by directors, and a title does not create them.
What does a chief sustainability officer earn?
No official statistic reports pay for the title.
The Home Office going rate for the nearest occupation group, SOC 2152, is £37,200 on a 37.5-hour week for the whole group.
ISEP’s 2025 report found an average of £91,911 for Fellow-grade members, which is an average of survey respondents at the senior grade, not a salary band.
Does the UK Corporate Governance Code require a CSO?
No. The Code’s Provision 29 asks the board to declare on the effectiveness of material controls, which the 2024 Code extends to reporting controls, for financial years beginning on or after 1 January 2026. It does not require any executive post.
Is there a gender pay gap in senior sustainability roles?
ISEP’s 2025 survey found a gender pay gap of 14.7% across respondents, up from 8.75% in 2022, and wider at senior management level. It describes survey respondents, not the whole workforce.
Is this site a recruiter for CSO roles?
No. It is an independent reference with no recruitment service, clients or candidates.
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.
- legislation.gov.ukCompanies Act 2006 s.250
“Director” includes any person occupying the position of director, by whatever name called.
- legislation.gov.ukCompanies Act 2006 s.172
The directors’ duty to promote the success of the company.
- legislation.gov.ukCompanies Act 2006 s.419
Approval and signature of the directors’ report.
- legislation.gov.ukCompanies Act 2006 s.414CB
The non-financial and sustainability information statement and the climate-related financial disclosures in the strategic report.
- legislation.gov.ukSI 2014/1643 reg 30
Responsible officers and the sign-off.
- Financial Reporting CouncilUK Corporate Governance Code 2024
Provision 29: the board’s declaration on material controls.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
Comply or explain across UK SRS for UKLR 6, 14, 15, 16 and 22, periods from 1 January 2027.
- Financial Conduct AuthorityPS26/19 (PDF): ¶¶2.45, 3.6, 3.12, 3.14, 3.20
Assurance statement, scope, reliefs and the explain statement.
- Financial Reporting CouncilISSA (UK) 5000
The FRC’s standard for sustainability assurance engagements, for voluntary use.
- legislation.gov.ukSI 2008/410 Sch 7 ¶20B
The SECR size test for unquoted companies: exempt if two or more “not more than” conditions are met.
- Home OfficeImmigration Rules Appendix Skilled Occupations
The going rate for SOC 2152: £37,200 on a 37.5-hour week.
- Office for National StatisticsStandard Occupational Classification 2020
Unit group 2152, Environment professionals.
- Office for National StatisticsAnnual Survey of Hours and Earnings
Earnings by occupation group, not by sustainability job title.
- ISEPState of the Sustainability Profession 2025 (short report)
Professional-body survey: roles, pay by grade, pay rises, gender pay gap.