Sustainability recruitment · role guides · checked 1 October 2026
ESG reporting manager: the calendar the role runs
An ESG reporting manager runs a calendar that starts at the financial year end, not at the first of January.
The accounts filing date, which carries SECR, sets the hard stop, and UK SRS for listed companies and ESOS add dates of their own.
This page works back from the year end and shows what each date means for the person preparing the report.
The calendar
Work back from the year end
Pick the year end and the company type.
The panel computes the accounts filing date and shows whether the period falls inside the FCA’s UK SRS rules.
The calendar has one fixed point that most teams treat as a target, and it is a hard legal stop.
Section 442 of the Companies Act 2006 allows nine months for a private company and six for a public one, and the date does not move for a weekend or a bank holiday.
SECR is part of the directors’ report, so that date is SECR’s date as well.
For a listed company the UK SRS disclosures sit in the annual financial report, so they follow the same timetable, with the explain statement written alongside.
ESOS stands outside the annual cycle: its dates are fixed by the scheme, not by the year end.
Work back from the year end
- 31 December 2027 · the accounting period ends; SECR figures are for this period.
- 30 September 2028 · latest date to file the accounts and directors’ report (9 months after the year end for a private company); it does not move for a weekend or bank holiday.
- UK SRS · for a listed company in scope, this period began on or after 1 January 2027, so it is within the FCA’s comply-or-explain rules.
- 5 December 2027 · ESOS Phase 4 notification of compliance, whatever the year end.
CA 2006 s.442(2) (the first accounting period of a new company follows a different rule); FCA PS26/19; Environment Agency ESOS Phase 4 milestones.
Not legal advice.
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The cycle
Five phases, worked backwards
The most reliable way to plan the cycle is to start from the filing date and subtract.
The data lock comes first after the year end, because every figure downstream depends on a boundary and a method that must not move.
Drafting follows, and for a listed company that means mapping each UK SRS requirement to a disclosure or an explanation, under the rules in PS26/19.
Review comes next, and here the controls matter: Provision 29 asks boards in the Code’s scope to declare on material controls, which the 2024 Code extends to reporting controls.
UK SRS S1 asks for data and assumptions consistent, so far as possible, with the financial statements, in its general requirements, so the review includes a reconciliation.
Board approval and filing close the cycle, and the board’s approval is where the legal responsibility sits, under section 419.
Those phases are a planning aid, not a legal sequence: only the filing date and the approval are fixed by the Act.
- Filing dateAccounts and directors’ report filed
Carries SECR; the date does not move for a weekend.
- Before filingBoard approval
The board approves the strategic and directors’ reports; a director or the secretary signs.
- Before approvalReview and controls
Evidence file checked; consistency with the financial statements tested.
- DraftingNarrative and explain statement
UK SRS mapping, SECR narrative, climate disclosures.
- After year endData lock and calculation
Boundary fixed, figures calculated, method noted.
What sits in the report
The regimes the cycle carries
SECR, from SI 2018/1155, applies to quoted companies at any size and to unquoted companies that exceed at least two of the limits in paragraph 20B.
The largest companies add the climate-related financial disclosures of section 414CB to the strategic report.
Listed companies add UK SRS, which the Department for Business and Trade published on 25 February 2026 and which is based on the ISSB’s IFRS S1 and S2, after the FCA’s consultation in CP26/5.
Our guides on SECR, UK SRS compliance, UK SRS S1 and UK SRS S1 and S2 take each in turn, and sustainability assurance covers the optional engagement.
The roles above and beside the reporting manager are the head of sustainability recruitment and the chief sustainability officer recruitment, and the ESG manager guide covers the disclosure desk.
For pay, the Home Office going rate for the nearest occupation is £37,200, and the salary guide shows how to read the rest.
The hub lists the other guides.
No UK rule requires sustainability disclosures to be assured.
A listed company states whether it obtained assurance and, if so, the provider, the disclosures covered and the standards used.
Sources: PS26/19 ¶2.45 · ISSA (UK) 5000
Frequently asked
ESG reporting manager, answered
What does an ESG reporting manager do?
Runs the annual reporting cycle for regulated and voluntary sustainability disclosures: collecting the data, applying the method, drafting the narrative, assembling the evidence file and taking the result through review and board approval.
The title has no legal definition and the duties follow the employer’s regimes.
When must a company file its accounts, and does that include SECR?
Section 442 of the Companies Act 2006 gives a private company nine months, and a public company six months, after the end of its accounting period.
SECR sits in the directors’ report, which is filed with the accounts, so the accounts deadline is SECR’s deadline, and it does not move for a weekend or bank holiday.
When do UK SRS reports have to be published?
For listed companies in UKLR 6, 14, 15, 16 and 22, the final rules apply to accounting periods beginning on or after 1 January 2027, so a calendar-year company’s first report covers 2027 and is published in 2028.
The disclosures sit in the annual financial report, so they follow its timetable.
Is UK SRS reporting mandatory?
Not in the strict sense.
UK SRS S1 and S2 are voluntary standards, and the FCA’s final rules in PS26/19 make them comply or explain for listed companies in scope.
What is required is the explain statement when a company does not comply in full.
What are the PS26/19 reliefs?
One year’s non-disclosure of Scope 3 emissions under UK SRS S2, and two years’ non-disclosure of non-climate matters under S1.
A company using a relief says so and, during the relief period, need give no further explanation.
Does an ESG reporting manager sign off the report?
No. The board approves the strategic and directors’ reports, and a director or the company secretary signs the directors’ report on its behalf.
The ESG reporting manager prepares the content and the evidence.
ESOS is signed by responsible officers, who are directors or people exercising management control.
Do ESG disclosures need to be assured?
No UK rule requires it.
A listed company states whether it obtained third-party assurance and, if so, the provider, the disclosures assured and the standards used.
The FRC’s ISSA (UK) 5000 is for voluntary use.
What is the ESOS date a reporting manager should plan around?
Phase 4 notification of compliance is due by 5 December 2027, whatever the company’s year end, and qualification is fixed on 31 December 2026.
The action plan is due by 5 December 2028.
How does an ESG reporting manager keep data consistent across disclosures?
By working from one inventory and one set of assumptions.
UK SRS S1 asks for data and assumptions consistent, as far as possible, with those used in the related financial statements, and the UK Corporate Governance Code’s Provision 29 asks boards in its scope to declare on material controls, which the 2024 Code extends to reporting controls.
What does an ESG reporting manager earn?
No official statistic reports pay for the title.
The Home Office going rate for the nearest occupation, SOC 2152, is £37,200 on a 37.5-hour week for the whole group, and the salary guide on this site shows how to read the professional-body figures.
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.
- 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.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
The standards, published 25 February 2026; voluntary for any UK entity not required by the FCA’s rules.
- Department for Business and TradeUK SRS S1 (PDF)
General requirements for disclosure of sustainability-related financial information.
- 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.ukCompanies Act 2006 s.419
Approval and signature of the directors’ report.
- legislation.gov.ukCompanies Act 2006 s.442
Time allowed for filing accounts: nine months for a private company, six for a public one.
- 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.
- legislation.gov.ukSI 2018/1155: Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018
The instrument that created SECR.
- Environment AgencyHow to comply with ESOS Phase 4
Milestone dates, qualification, lead assessor, sign-off.
- Financial Reporting CouncilUK Corporate Governance Code 2024
Provision 29: the board’s declaration on material controls.
- Financial Reporting CouncilISSA (UK) 5000
The FRC’s standard for sustainability assurance engagements, for voluntary use.
- 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.
- ISEPState of the Sustainability Profession 2025 (short report)
Professional-body survey: roles, pay by grade, pay rises, gender pay gap.