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Sustainability reporting · UK

Sustainability reporting in the UK: what it is, what binds, where it goes

Sustainability reporting in the UK is not one report: it is a set of duties with different populations, from SECR in the directors’ report to UK SRS in a listed company’s annual financial report.

Under the FCA’s final rules, listed companies in five categories report against UK SRS on a comply-or-explain basis for periods from 1 January 2027.

This page explains the frameworks, works out which ones reach your company and shows where each disclosure goes.

Definition

What sustainability reporting is, depending on who is asking

Sustainability reporting is the disclosure, usually in or alongside the annual report, of a company’s emissions, energy use, climate and nature risks, and the plans and targets it has for them.

What goes in depends on the question the framework asks.

The UK standard asks the investor’s question: UK SRS S1 ¶1 requires information about sustainability-related risks and opportunities that is useful to primary users of general purpose financial reports — existing and potential investors, lenders and other creditors.

That is financial materiality, and UK SRS S1 sets no numeric thresholds for it: materiality is judged, and reassessed at each reporting date.

The EU’s ESRS ask two questions at once — how sustainability affects the company and how the company affects people and the environment — which is double materiality.

The GRI Standards start from a company’s most significant impacts, and no UK instrument requires them.

The international baseline is the ISSB’s, explained on the ISSB framework; UK SRS is the UK’s version of it.

Law, rule or request

Mandatory, comply-or-explain, or asked for

Sources: SI 2008/410 Sch 7 Part 7A; CA 2006 s.414CA; FCA PS26/19; PPN 006.
FrameworkStatusWho
SECRLawQuoted companies; large unquoted companies and LLPs
Climate-related financial disclosureLawCompanies Act categories with more than 500 employees
ESOS schemeLawLarge undertakings and their UK groups
UK SRS S1 and S2Listing rule: comply or explain from 2027UKLR 6, 14, 15, 16 and 22
UK SRS S1 and S2VoluntaryEvery other UK entity
UK ETSLawCovered installations, aircraft operators and ships
Packaging EPRLawPackaging producers above the size tests
Plastic Packaging TaxTaxManufacturers and importers of 10 tonnes or more
Carbon Reduction PlanCondition of biddingSuppliers to in-scope central government contracts
TNFDVoluntaryAny company
SBTi targetsVoluntaryAny company

GOV.UK’s UK SRS guidance says the standards are available for voluntary use by any entity that chooses to do so.

The listing-rule obligation is narrower than “mandatory”: a listed company in scope discloses against UK SRS or says what it has not disclosed, why, and what it plans to do.

The Companies Act climate duty is implemented through SI 2022/31, which amended ss.414CA and 414CB, and it continues alongside the FCA’s rules.

The FCA’s rules replace its TCFD-aligned listing rule for periods from 1 January 2027; TCFD explains the four pillars both share, and the FCA’s reporting requirements page sets out the firms’ side.

Which regimes apply to us?

Your reporting stack, and where each part goes

The builder applies each regime’s own test to the figures you enter and says where the disclosure sits: annual financial report, strategic report, directors’ report, a notification, or a published plan.

The tests differ, which is the point of running them separately.

SECR’s unquoted test is two of more than 250 employees, more than £36m turnover and more than £18m balance sheet, in paragraph 20B of Schedule 7.

Those figures did not move when the Companies Act size thresholds rose in April 2025, because SECR carries its own.

ESOS asks for 250 or more employees, or turnover above £44m and balance sheet above £38m together, on 31 December 2026; SI 2026/701 amended the scheme for Phase 4.

The Companies Act climate duty needs more than 500 employees on every route, plus a listing, banking or insurance status, or turnover above £500m.

A UK listed company typically owes SECR as a quoted company, the climate duty, ESOS if its group is large, and UK SRS on comply or explain.

A large private company owes SECR and ESOS, and the climate duty only above 500 employees and £500m; UK SRS is voluntary for it, and the modernising corporate reporting consultation proposes no threshold for private companies.

An SME supplier usually owes nothing by law, and answers requests instead: a Carbon Reduction Plan, a customer’s ESG questionnaire, or an EU customer’s CSRD request, which the VSME cap limits.

The framework-by-framework detail is on ESG reporting requirements in the UK.

Your reporting stack · and where each part goes

UK SRS S1 and S2Voluntary

Where: Wherever you choose; usually the annual report

Only the five listing categories report under the FCA’s rules; for everyone else the standards are voluntary.

SECRLaw

Where: Directors’ report

You meet at least two of more than 250 employees, more than £36m turnover and more than £18m balance sheet; UK energy, emissions, an intensity ratio and efficiency action.

Climate-related financial disclosureNot caught

Where: —

The duty needs more than 500 employees on every route.

ESOS Phase 4Law

Where: A notification to the Environment Agency by 5 December 2027 — not a published report

At least 250 employees, or turnover above £44m and balance sheet above £38m, tested on 31 December 2026 across the UK group.

Sources: FCA PS26/19 ¶¶3.6–3.7; SI 2008/410 Sch 7 Part 7A; CA 2006 s.414CA; SI 2014/1643 as amended; PPN 006; Directive (EU) 2026/470.

The Companies Act duties apply to UK-registered companies and LLPs.

Simplified: SECR’s low-energy statement, group and subsidiary exemptions, the year-on-year size rules and the EU tests are in each regime’s own page.

Nothing you enter is stored or sent.

Four common company types

What applies, what to do, and by when

Each answer is provisional: size tests, group structures and listing categories decide the detail. Sources: PS26/19; Sch 7 para 20B; ESOS Phase 4; Accounting Directive.
CompanyAppliesWhat to doBy when
UK listed company (UKLR 6)SECR as a quoted company; the Companies Act climate duty above 500 employees; ESOS if the group is large; UK SRS on comply or explainMap existing climate disclosures against UK SRS S2, decide whether to use the Scope 3 and S1 reliefs, and plan the four statements in UKLR 6.6.6RPeriods from 1 January 2027; first report within four months of the 2027 year end; ESOS by 5 December 2027
Large private companySECR if two of the three limbs are exceeded; ESOS on its own test; the climate duty only above 500 employees and £500m turnover; UK SRS voluntaryRun the SECR and ESOS tests separately — they differ, and SECR’s did not rise with the 2025 size upliftEvery directors’ report; ESOS notification by 5 December 2027
SME supplierUsually no UK duty of its own; requests arrive insteadMeasure Scope 1 and 2 once with the right year’s DESNZ factors, and answer every request from the same figuresWhen a tender or questionnaire arrives; a Carbon Reduction Plan at the point of bidding
Group with EU operationsCSRD through an EU subsidiary or listing above the Omnibus thresholds, or Article 40a; UK duties apply alongsideWork out which entity reports under which regime, and build one emissions dataset for bothCSRD from financial year 2027 under Omnibus I; CSDDD from 26 July 2029

The overlap is the opportunity: SECR’s energy and emissions data is the starting inventory for UK SRS S2, and an ESOS assessment’s savings opportunities are the raw material for a transition plan.

Governance can be aligned too: one board committee, one set of controls over the data, and one owner for each figure, whichever report it appears in.

What does not carry across is scope: SECR for an unquoted company is UK-only, while UK SRS and CSRD reports cover the group, so the boundary has to be set once and stated in each report.

Sustainability reporting frameworks

Every framework a UK company meets, on one map

Sources: DBT; SI 2008/410; Environment Agency; EUR-Lex.
FrameworkWhat it isBinds?
UK SRS S1General requirements: governance, strategy, risk management, metrics and targets for sustainability-related risksComply or explain for listed categories from 2027
UK SRS S2Climate-related disclosures, including Scope 1, 2 and 3 emissionsComply or explain for listed categories from 2027
SECR reportingEnergy use, emissions, an intensity ratio and efficiency action in the directors’ reportLaw since 1 April 2019
ESOSA four-yearly energy assessment, notified to the Environment AgencyLaw; Phase 4 by 5 December 2027
Transition plansA plan for the transition; listed companies say whether they have oneNo duty to have one
DESNZ conversion factorsThe emission factors behind most UK reports; the 2026 set was published on 11 June 2026A tool, not a regime
SBTiVoluntary targets; the Corporate Net-Zero Standard V2.0, published 11 June 2026, applies to validations from 1 February 2027Voluntary
CSRD (EU)EU sustainability reporting after Omnibus I: more than 1,000 employees and €450mEU law; reaches UK groups indirectly
CSDDDEU due diligence duty, applying from 26 July 2029EU law
VSMEVoluntary EU standard for smaller companies, Delegated Regulation (EU) 2026/1560Voluntary; caps value-chain requests

CSRD after the Omnibus reaches UK groups through EU subsidiaries, EU listings and Article 40a, as CSRD reporting for UK companies sets out.

A group reporting under both systems should start from CSRD vs UK SRS and build one emissions dataset for both.

The carbon-pricing and packaging regimes are law for those they cover but are not disclosures: the UK ETS, packaging EPR and Plastic Packaging Tax each have their own returns.

Where UK SRS goes

Inside the annual financial report, with four statements

For a listed company in scope, the disclosures belong in the annual financial report under UKLR 6.6.6R.

The rule asks for a compliance statement against UK SRS S2 and UK SRS S1, and where a company has not disclosed, an explanation of what is missing, why, and the steps it plans.

It adds three statements: where the disclosures can be found, whether assurance was obtained and on what basis, and — for UKLR 6, 16 and 22 companies — whether the company has a climate-related transition plan and where it is.

The list of UK SRS S1 paragraphs to apply sits in guidance, UKLR 6.6.6A G, not in the rule.

The annual financial report must be public within four months of the end of the financial year, which fixes the reporting calendar.

iXBRL tagging applies to IFRS consolidated financial statements; PS26/19 sets no tagging requirement for sustainability disclosures.

SECR sits in the directors’ report and the Companies Act climate disclosures in the strategic report, so a listed company’s annual report carries all three in different places.

The requirement-by-requirement reading is on UK SRS compliance, and the dates on the UK SRS S1 and S2 timeline.

4 months
To publish the annual financial report after year end
DTR 4.1.3R
No tagging
PS26/19 sets no iXBRL requirement for sustainability disclosures
PS26/19 ¶¶2.77–2.81

How a report is built

Six steps from data to a compliance statement

Sources: UK SRS S1; GHG Protocol; FRC; PS26/19.
StepWhat it involvesAnchor
1. ScopeWhich regimes apply, to which entity, from which periodThe builder above; each regime’s own test
2. MaterialityWhich sustainability-related risks and opportunities could reasonably affect prospectsUK SRS S1 ¶¶B19, B25, B28
3. InventoryScope 1 and 2, then Scope 3, on a consistent boundaryGHG Protocol Corporate Standard; DESNZ factors
4. GovernanceBoard oversight, management roles, controls over the dataUK SRS S1 governance; the UK Corporate Governance Code
5. DisclosureDraft against S1 and S2, or record what is omitted and whyUKLR 6.6.6R(7A), (7B)
6. Assurance and sign-offDecide whether to commission assurance and state it either wayUKLR 6.6.6R(8); ISSA (UK) 5000 if commissioned

The inventory is the heaviest step for most companies, and SECR data is the natural start: it already covers energy and Scope 1 and 2, using the method in the government’s environmental reporting guidelines.

Scope 3 is where UK SRS goes beyond SECR, and a listed company has one year of relief from disclosing it under the FCA’s rules.

Governance sits with the board, and the FRC’s UK Corporate Governance Code is the frame most listed companies already report against.

Assurance is optional: the FRC’s ISSA (UK) 5000 governs the engagement if one is commissioned, and sustainability assurance covers who may provide it.

Software helps with the data, and the two layers are tested differently: carbon accounting software builds the inventory, and carbon reporting software produces the disclosure.

A gap check against all six steps is on the UK SRS readiness assessment.

No regulator publishes a preparation timetable; any lead time you see quoted is an adviser’s estimate.

SECR

The regime most companies already report under, and it is bigger than forecast

SECR has applied since 1 April 2019 to every quoted company and to large unquoted companies and LLPs, after the government’s 2018 consultation.

DESNZ’s independent evaluation of January 2026 counts about 19,900 companies and LLPs in scope, against 11,300 forecast — about 76% more.

The 2026 post-implementation review restates those figures and recommends retaining SECR with amendments, not replacing it.

Quoted companies report global Scope 1 and 2 emissions and energy; unquoted companies and LLPs report UK energy and emissions, with a narrow transport-fuel Scope 3 limb.

Every SECR report carries at least one intensity ratio and a narrative on energy efficiency action; SECR covers the rules in full.

About 19,900
Companies and LLPs in SECR scope
DESNZ evaluation, January 2026
11,300
Forecast when SECR was introduced
DESNZ evaluation, January 2026

ESOS

An assessment, not a report

ESOS asks a large undertaking to measure its total energy use, audit the significant part and identify savings, then notify the Environment Agency.

Phase 4 runs from 6 December 2023 to 5 December 2027, with qualification tested on 31 December 2026, as the Environment Agency’s Phase 4 guidance explains.

The ESOS results do not have to be published, though they feed a transition plan and the energy narrative in SECR.

The step-by-step route is on the ESOS Phase 4 compliance guide.

UK SRS and the ISSB

Close to IFRS S1 and S2, not identical

UK SRS S1 and S2 were published by the Department for Business and Trade on 25 February 2026, as the UK’s versions of the ISSB’s IFRS S1 and S2.

The government removed the effective dates so that timing could be set by others — which the FCA has now done for listed companies.

In the standards, the climate-first relief and the Scope 3 relief carry no time limit, and most references to the industry-based guidance say “may” rather than “shall”.

The one stricter addition is UK SRS S2 ¶B59A, on financed emissions.

The FCA’s rules then give listed companies one year of Scope 3 relief and two years for non-climate UK SRS S1 matters, from first application.

Compliance with UK SRS is therefore not automatically compliance with the ISSB standards; the FRC’s sustainability reporting FAQs cover the UK frame.

How the rules developed, from CP26/5 to PS26/19, is tracked on the CP26/5 tracker; CP26/5 itself is here as a PDF.

Support

Where to go next, by what you need

Professional bodies publish technical guidance; ICAEW wrote on how listed companies’ sustainability disclosures were set to evolve in February 2026, before the final rules.

For hands-on delivery, specialist sustainability consultants build the figures and disclosures.

For the standards in depth, sustainabilityreportingstandards.co.uk is our editorial reference; srs.green maps the environmental regimes, and srsreport.com covers the report as a document.

Or start at the UK SRS home page, or book a free 15-minute call with our network of specialists.

Test yourself

Seven claims about sustainability reporting, true or false

Most errors in circulation come from pages written before the final rules: “mandatory UK SRS from 2027”, “515 companies must comply”, “assurance required”.

Each answer names the provision that settles it.

A frequent overstatement

UK sustainability reporting is not a single mandatory standard: it is overlapping duties with different populations, and UK SRS reaches listed companies through comply-or-explain listing rules.

Sustainability reporting: true or false?

  1. UK SRS is mandatory for UK listed companies from 2027.

  2. UK SRS S1 and S2 are word for word IFRS S1 and S2.

  3. SECR’s thresholds rose with the April 2025 Companies Act size uplift.

  4. More companies are in SECR scope than the government predicted.

  5. Every UK company must publish a Carbon Reduction Plan.

  6. The FCA requires UK SRS disclosures to be iXBRL-tagged.

  7. UK SRS S1 sets percentage thresholds for materiality.

0 of 7 answered.

Nothing you choose is stored or sent.

Frequently asked

Sustainability reporting, answered

What is sustainability reporting?

A company’s public account of its emissions, energy use, climate and other sustainability risks, and its plans and targets for them, usually in or alongside the annual report.

UK SRS asks how sustainability matters affect the company’s prospects, for investors and lenders; the EU’s ESRS also ask how the company affects people and the environment; GRI starts from the company’s most significant impacts.

Is sustainability reporting mandatory in the UK?

Parts of it are.

SECR is law for quoted companies, large unquoted companies and large LLPs; the Companies Act climate-related financial disclosure duty is law for companies with more than 500 employees in its categories; ESOS is law for large undertakings.

UK SRS is voluntary for any entity, and under the FCA’s final rules listed companies in five categories report against it on a comply-or-explain basis from 2027.

Is UK SRS mandatory for listed companies?

No. PS26/19 requires 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 reporting in 2028.

A company that does not disclose says what is missing, why, and the steps it plans.

Where does a UK SRS report go?

In the annual financial report, under UKLR 6.6.6R.

The rule also requires a statement of where the disclosures are, a statement about any assurance obtained, and, for UKLR 6, 16 and 22 companies, a statement of whether the company has a climate-related transition plan and where to find it.

How many companies report under SECR?

About 19,900 companies and LLPs, according to DESNZ’s independent evaluation of January 2026, against 11,300 forecast when SECR was introduced.

The 2026 post-implementation review restates the figure and recommends keeping SECR with amendments.

What is UK SRS reporting guidance?

The standards themselves, published by the Department for Business and Trade with GOV.UK guidance on their use, and the FCA’s listing rules and draft Technical Note TN 803.1 on how to comply or explain.

The FCA’s draft guidance was open for comment until 28 October 2026.

Are UK SRS S1 and S2 the same as IFRS S1 and S2?

Not word for word.

The UK versions remove the effective dates, leave the climate-first and Scope 3 reliefs without a time limit in the standards, mostly turn “shall” into “may” for the industry-based guidance, and add a stricter paragraph on financed emissions, UK SRS S2 ¶B59A.

The FCA’s rules then set one-year and two-year reliefs for listed companies.

Does a sustainability report need assurance?

Not under the FCA’s rules.

A listed company states whether it obtained assurance and, if so, from whom, over what and to which standards.

The FRC’s ISSA (UK) 5000 governs an engagement if one is commissioned; it requires no one to obtain assurance.

Do small companies have to do sustainability reporting?

Usually not by law.

What reaches them are requests: a Carbon Reduction Plan to bid for central government contracts above £5m a year, customer questionnaires, and data requests from EU customers, which the VSME value-chain cap limits for suppliers with 1,000 employees or fewer.

Does the EU CSRD apply to UK companies?

Not as UK law.

It reaches UK groups through EU subsidiaries or EU listings above 1,000 employees and €450m net turnover, and through Article 40a for a non-EU parent with EU turnover above €450m in each of the last two years and an EU subsidiary or branch above €200m.

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 14 sources fromFCADBTFCA Handbooklegislation.gov.ukDESNZEnvironment Agency
  1. FCA
    PS26/19: Aligning listed issuers’ sustainability disclosures with international standards

    Comply or explain across UK SRS for UKLR 6, 14, 15, 16 and 22; six categories excluded (¶3.7).

  2. FCA
    PS26/19 (PDF), including the made rule text

    UKLR 6.6.6R(7A), (7B) and (8); the reliefs at UKLR TP 16.

  3. DBT
    UK SRS S1 and UK SRS S2

    Published 25 February 2026; available for voluntary use by any entity.

  4. DBT
    UK SRS S1 (PDF)

    Objective (¶1); materiality (¶¶B19, B25, B28).

  5. FCA Handbook
    DTR 4.1 — the annual financial report

    Public within four months of year end (DTR 4.1.3R).

  6. legislation.gov.uk
    SI 2008/410 Schedule 7 Part 7A — SECR

    Quoted companies and large unquoted companies; the size test at para 20B.

  7. DESNZ
    Independent evaluation of SECR (29 January 2026)

    About 19,900 companies and LLPs in scope, against 11,300 forecast.

  8. DESNZ
    2026 post-implementation review of the SECR Regulations

    Recommends retaining SECR with amendments.

  9. legislation.gov.uk
    Companies Act 2006, s.414CA

    Who owes climate-related financial disclosures in the strategic report.

  10. Environment Agency
    Comply with ESOS Phase 4

    Qualification on 31 December 2026; compliance by 5 December 2027.

  11. Cabinet Office
    PPN 006: Carbon Reduction Plans

    A condition of participation for in-scope contracts above £5m a year; policy, not law.

  12. EUR-Lex
    Accounting Directive, consolidated to 18 March 2026

    CSRD scope after Omnibus I: 1,000 employees and €450m; Article 40a.

  13. IFRS Foundation
    International Sustainability Standards Board

    IFRS S1 and S2, the baseline UK SRS adopts.

  14. GHG Protocol
    Corporate Standard

    The inventory method UK SRS S2 and SECR reporting rest on.

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