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Sustainability recruitment · role guides · checked 1 October 2026

ESG analyst: which rule each datapoint answers

An ESG analyst works at the level of the datapoint, and the skill is knowing which rule, paragraph or request each figure answers.

This page crosswalks seven common datapoints to the instrument behind them and names the trap in each, such as offsets that cannot be netted off.

It sets out the credentials as routes, not requirements, and gives the one official pay figure with its limits.

The datapoint

Which rule does it answer?

Pick a datapoint.

The panel names the instrument and paragraph it answers, and the trap that makes the figure wrong.

Most analyst errors are not arithmetic: they are a datapoint answering the wrong paragraph.

The clearest example is the net figure: UK SRS S2 paragraph 29(a) asks for absolute gross emissions, and the word gross is the control.

A figure net of offsets does not satisfy it, and SECR has no netting-off provision either.

The second most common error is the intensity ratio: SECR asks for at least one emissions ratio chosen by the company, and an energy ratio alone does not meet it.

The third is the Scope 3 relief: the FCA’s final rules allow one year’s non-disclosure of Scope 3 for listed companies, and a company using it must say so, as PS26/19 paragraph 3.14 sets out.

The inventory behind the datapoints is the subject of the carbon manager guide, and the ESG reporting manager guide covers the calendar they feed.

Which rule does a datapoint answer?

UK SRS S2 ¶29(a)

Answers: UK SRS S2 absolute gross emissions, classified by scope.

The trap: The word “gross” is the control: a figure net of offsets does not satisfy the paragraph, and SECR has no netting-off provision either.

Paragraph references are to the instruments as published.

Not legal advice.

Nothing you pick is stored or sent.

Consistency

One figure, said once

UK SRS S1 asks for connected information, and its paragraph 23 asks for data and assumptions consistent, as far as possible, with the financial statements.

A company in the climate-disclosure scope of section 414CA and ESG data management practice faces the same issue between the strategic report, the directors’ report and any voluntary disclosure.

ESOS Phase 4 adds a new datapoint to the stock: the energy savings achieved in the compliance period, described in the Environment Agency’s Phase 4 guidance.

The Scope 3 datapoints follow the GHG Protocol categories, and the guide to UK SRS Scope 3 reporting explains how listed companies treat them.

Tooling follows the data, and the guide to carbon reporting software describes what vendors publish about their own products.

The test of a datapoint

Can you say, for each figure, which paragraph it answers and where else it appears?

If not, it is a candidate for an inconsistency between disclosures.

Getting there

Credentials are routes, not requirements

No qualification is required by law to be an ESG analyst.

On the investment side, the CFA Institute’s Sustainable Investing Certificate is a common optional choice, and on the environment side ISEP’s skills map sets out the competencies.

The National Careers Service profile lists a level 4 apprenticeship, and ONS classifies the work by duties in SOC 2020 unit group 2152.

The Home Office going rate for that group is £37,200 on a 37.5-hour week, covering every grade, and the salary guide says how to read it.

The GHG Protocol’s Corporate Standard and the consultation paper CP26/5 are the two documents most analyst job descriptions assume the candidate has read.

The hub lists the other guides in this series.

At a glance

Datapoint, paragraph, trap

Paragraph references are to the instruments as published. Not legal advice.
DatapointParagraphThe trap
Gross Scope 1, 2, 3UK SRS S2 ¶29(a)Never net of offsets
Energy in kWh (quoted)SI 2008/410 Sch 7 ¶15(3A)40,000 kWh or less is a conditional relief, not an exemption
Intensity ratioSch 7 ¶17 / ¶20GAt least one, an emissions ratio
Net targetUK SRS S2 ¶36(c)Gross target must also be given
Scope 3 (listed)PS26/19 ¶3.14One-year relief, stated
Energy savings achieved (ESOS)SI 2026/701, Chapter 3BOnly the combined saving is published

Frequently asked

ESG analyst, answered

What does an ESG analyst do?

Collects, checks and structures the data behind sustainability disclosures and requests: emissions, energy, workforce and governance datapoints, mapped to the rule or questionnaire each one answers.

The title has no legal definition, and some analysts work for companies while others work in investment firms analysing other companies.

What datapoints does UK SRS S2 require?

Among others, absolute gross greenhouse gas emissions classified by Scope 1, 2 and 3 in paragraph 29(a), and, where an entity discloses a net target, the associated gross target separately under paragraph 36(c).

Offsets are never deducted from the gross figure.

Can carbon offsets be deducted from reported emissions?

No. UK SRS S2 requires gross emissions, and SECR contains no netting-off provision.

Offsets can be disclosed separately but are not deducted from the reported total.

What is the SECR intensity ratio?

A ratio that expresses the company’s annual emissions in relation to a quantifiable factor associated with its activities.

The directors’ report must state at least one, and the company chooses it. It is an emissions ratio, not an energy ratio.

What is the 40,000 kWh threshold in SECR?

A conditional relief from disclosing certain energy and emissions information for a company using 40,000 kWh or less of UK energy, with one version for quoted and one for unquoted companies.

It is a disclosure relief, not an exemption from SECR, and it is 40,000 kWh, never 40 MWh.

Is Scope 3 reporting required?

For listed companies, UK SRS S2 includes Scope 3 and the FCA’s final rules allow one year’s non-disclosure of it as a relief, which a company using it must state.

For other companies, UK SRS is voluntary, and SECR requires only the transport-fuel element of Scope 3 for unquoted companies.

What qualifications does an ESG analyst need?

None is required by law.

Investment-side analysts often take the CFA Institute’s Sustainable Investing Certificate, and environment-side analysts the ISEP route.

The National Careers Service lists a level 4 apprenticeship for corporate responsibility and sustainability practitioners.

What does an ESG analyst earn?

No official statistic reports pay for ESG analysts.

The Home Office going rate for the nearest occupation group, SOC 2152, is £37,200 on a 37.5-hour week and covers every grade in the group.

The salary guide shows how far to rely on it.

What new datapoints does ESOS Phase 4 add?

The energy savings actually achieved in the compliance period: a description of each measure implemented, the saving in kWh and its category.

Only the combined saving is published, and per-measure figures are not.

Why does consistency across disclosures matter?

UK SRS S1 asks for data and assumptions consistent, as far as possible, with those used in the related financial statements, so one datapoint reported differently in two places is a finding waiting to happen.

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 16 sources fromDepartment for Business and TradeFinancial Conduct Authoritylegislation.gov.ukGOV.UKGHG ProtocolEnvironment Agency
  1. Department for Business and Trade
    UK SRS S2 (PDF): ¶29(a), ¶36(c)

    Gross emissions by scope, and the gross target alongside any net target.

  2. Department for Business and Trade
    UK SRS S1 (PDF)

    General requirements for disclosure of sustainability-related financial information.

  3. Financial Conduct Authority
    PS26/19 (PDF): ¶¶2.45, 3.6, 3.12, 3.14, 3.20

    Assurance statement, scope, reliefs and the explain statement.

  4. legislation.gov.uk
    SI 2008/410 Sch 7 ¶20B

    The SECR size test for unquoted companies: exempt if two or more “not more than” conditions are met.

  5. legislation.gov.uk
    SI 2008/410 Sch 7 Part 7A

    The energy and carbon report for large unquoted companies.

  6. GOV.UK
    Environmental reporting guidelines, including mandatory greenhouse gas emissions reporting guidance

    Government methodology guidance for SECR and greenhouse gas reporting.

  7. GHG Protocol
    Corporate Accounting and Reporting Standard

    Scopes 1 and 2 and the consolidation approaches.

  8. GHG Protocol
    Scope 2 Guidance

    Location-based and market-based reporting.

  9. GHG Protocol
    Corporate Value Chain (Scope 3) Standard

    The fifteen Scope 3 categories.

  10. legislation.gov.uk
    Companies Act 2006 s.414CB

    The non-financial and sustainability information statement and the climate-related financial disclosures in the strategic report.

  11. Environment Agency
    How to comply with ESOS Phase 4

    Milestone dates, qualification, lead assessor, sign-off.

  12. legislation.gov.uk
    SI 2026/701: ESOS (Amendment) Regulations 2026

    Phase 4 changes, including energy savings achieved and the third progress update.

  13. ISEP
    Sustainability Skills Map

    The professional body’s competency map for sustainability roles.

  14. Home Office
    Immigration Rules Appendix Skilled Occupations

    The going rate for SOC 2152: £37,200 on a 37.5-hour week.

  15. Office for National Statistics
    Standard Occupational Classification 2020

    Unit group 2152, Environment professionals.

  16. National Careers Service
    Corporate responsibility and sustainability practitioner

    Official job profile and apprenticeship routes.

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