Sustainability recruitment · role guides · checked 1 October 2026
Head of sustainability: write the remit before the advert
A head of sustainability job fails or works on its remit: which regimes it covers, what it prepares and what only directors can approve.
The builder below turns a tick-list of regimes into a remit text that separates the preparer’s duties from the approvals the law gives elsewhere.
The page then sets out the split in a table, and why a seniority title is not the same as a director’s duty.
The remit
A remit that separates the work from the sign-off
Tick the items in the remit.
The text updates and is ready to copy into a job description or a board paper.
A remit that says “responsible for SECR, ESOS and UK SRS” promises something the law does not allow a head of sustainability to deliver alone.
The directors’ report is approved by the board and signed by a director or the secretary, under section 419 of the Companies Act 2006.
ESOS is signed by responsible officers, and the FCA’s final rules in PS26/19 leave the annual financial report with the board.
A good remit says what the head prepares, what the head recommends and what the head does not hold, and it says so in the advert.
That protects the post-holder, who is otherwise accountable for approvals they cannot give.
Write the remit before the advert
A drafting aid built from the provisions named in each line.
Not legal advice.
Nothing you tick is stored or sent.
The split
Prepare, recommend, approve
| Duty | Who does the work | Who approves or signs |
|---|---|---|
| SECR figures, method and intensity ratio | Head of sustainability (or their team) | The board approves the directors’ report; a director or the secretary signs |
| ESOS data, lead assessor, action plan | Head of sustainability (or their team) | Responsible officers sign |
| UK SRS mapping and explain statement | Head of sustainability with finance | The board is responsible for the annual financial report |
| Targets and the reduction plan | Head proposes | The board decides whether to adopt |
| Assurance | Head prepares the brief and evidence | The company decides whether to obtain it |
Seniority does not move the approvals.
A head of sustainability who is not on the board does not become a director by title, because the Companies Act looks to the position occupied, not the name.
The chief sustainability officer guide tests that line directly.
The Code’s Provision 29 adds a board declaration on material controls that the 2024 Code extends to reporting, so the head’s evidence file is also the board’s.
Assurance and claims
Two decisions that are not the head’s
Whether to obtain assurance is the company’s decision, and the head prepares the brief and the evidence; the sustainability assurance guide sets out the options.
What the company says in public is also the company’s: a financial firm’s sustainability claims face the FCA’s anti-greenwashing rule in ESG 4.3.1R.
The head’s job is to make both decisions easier to take, with evidence.
The consultation CP26/5 preceded the final rules, and UK SRS compliance, UK SRS S1 and UK SRS S1 and S2 go through each limb.
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
Pay evidence
What can be said about pay
No official statistic reports pay for a head of sustainability.
The Home Office going rate for the nearest group, SOC 2152, is £37,200 on a 37.5-hour week, and it covers every grade in the group, as the ONS classification defines it.
ISEP’s 2025 survey found an average of £91,911 for its Fellow grade and a gender pay gap that widened to 14.7%, and it is wider at senior level.
The Annual Survey of Hours and Earnings is the underlying official source, and the salary guide shows how to read it.
The statutory calendar the function runs is in the main head of sustainability guide, the accountability map is in the sustainability director guide, and the ESG reporting manager guide works the cycle back from the year end.
The hub lists the other guides in this series.
Frequently asked
Head of sustainability, answered
What does a head of sustainability do?
Leads the sustainability function: the programme, the regulated reporting, the targets and the team.
The title has no legal definition, so the remit, not the title, says what the job is.
What should a head of sustainability remit include?
The regimes the employer is in, what the post-holder prepares for each, and what the law gives to directors.
The remit builder above turns a tick-list of regimes into a text that separates the two.
Is a head of sustainability 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 head of sustainability is a director only if they occupy that position, usually by being on the board.
Who signs the SECR report?
A director or the company secretary signs the directors’ report on the board’s behalf, under section 419 of the Companies Act 2006.
A head of sustainability prepares the content but is not the signatory unless they are also a director.
Who signs off ESOS?
Responsible officers: directors or people exercising management control.
A head of sustainability may qualify as a person exercising management control, which is a question of fact for each company.
What does a head of sustainability 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 and covers every grade.
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 head of sustainability decide whether to get assurance?
No UK rule requires assurance, so the decision is the company’s.
A listed company states whether it obtained assurance and, if so, the provider, the disclosures assured and the standards used.
The head prepares the brief and the evidence.
Should a head of sustainability report to the CFO or the CEO?
The law does not say.
The accountability that matters is who approves the reports: the board approves the strategic and directors’ reports, and the UK Corporate Governance Code’s Provision 29 asks boards in its scope to declare on material controls, including over reporting.
What is the 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 head of sustainability 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.419
Approval and signature of the directors’ report.
- legislation.gov.ukSI 2014/1643 reg 30
Responsible officers and the sign-off.
- 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.
- 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 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.
- FCA HandbookESG 4.3.1R: anti-greenwashing rule
Sustainability claims must be fair, clear and not misleading.
- legislation.gov.ukCompanies Act 2006 s.172
The directors’ duty to promote the success of the company.
- legislation.gov.ukCompanies Act 2006 s.250
“Director” includes any person occupying the position of director, by whatever name called.
- ISEPState of the Sustainability Profession 2025 (short report)
Professional-body survey: roles, pay by grade, pay rises, gender pay gap.
- 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.
- Environment AgencyHow to comply with ESOS Phase 4
Milestone dates, qualification, lead assessor, sign-off.