Sustainability reporting requirements in the UK: every regime in one place

There is no single UK sustainability reporting law.

The main requirements are the FCA’s UK SRS rules for listed companies, the Companies Act climate-related financial disclosures and non-financial statement, the section 172(1) statement, SECR, ESOS, the FCA’s ESG sourcebook for asset managers, the climate rules for large pension schemes, carbon reduction plans for large government contracts, modern slavery statements, gender pay gap reporting, payment practices reporting, packaging EPR data, UK ETS emissions reports and, from 2027, CBAM returns. Each has its own scope test.

Some of it is, for some companies, and each regime sets its own test.

Large companies face Companies Act duties such as SECR and the section 172(1) statement; listed companies face the FCA’s comply-or-explain UK SRS rules from 2027; and most small and medium-sized companies face none of the corporate disclosure duties unless they bid for large government contracts, trade in packaging or import CBAM goods.

Not under the corporate disclosure regimes, which all have size or listing tests.

A smaller business can still be caught by PPN 006 when bidding for a central government contract above £5m a year, by packaging EPR above £1m turnover and 25 tonnes, by CBAM above £50,000 of CBAM goods imported in 12 months, or by the UK ETS if it runs a covered installation.

Only companies listed in UKLR 6, 14, 15, 16 and 22, under the FCA’s PS26/19, on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

For every other entity UK SRS S1 and S2 are voluntary.

Under section 414CA of the Companies Act, companies with more than 500 employees that are traded, banking, insurance or insurance-market companies, AIM companies, or have turnover over £500 million, unless they qualify as small or medium-sized.

LLPs have a parallel test under SI 2022/46.

Every quoted company reports.

A large unquoted company or large LLP reports when it exceeds two of: £36 million turnover, £18 million balance sheet total and 250 employees, on the two-year rule.

The figures were not raised in April 2025 when the Companies Act size limits rose.

A UK undertaking, or group, with 250 or more employees, or with annual turnover over £44 million and a balance sheet over £38 million, on 31 December 2026.

It must notify the Environment Agency of compliance by 5 December 2027.

Yes, under the FCA’s ESG sourcebook: a TCFD entity report for firms with £5 billion or more of assets in scope on a three-year rolling average, an entity-level sustainability report under ESG 5 for the same population, label and naming rules where sustainability labels or restricted terms are used, and the anti-greenwashing rule for every authorised firm.

Trustees of occupational schemes with relevant assets of £1 billion or more, and all authorised master trusts and authorised collective money purchase schemes, under SI 2021/839.

The report is due within seven months of the scheme year end, and failure to publish it carries a mandatory penalty.

Only when bidding for a contract from an in-scope central government body that applies PPN 006 and whose value is above £5 million a year, averaged over the life of the contract and including VAT.

PPN 006 is a procurement policy, not a legal duty on companies.

From 1 January 2027 an importer of £50,000 or more of CBAM goods in 12 months must register for CBAM, with the first registration deadline of 31 January 2028 and the first return and payment by 31 May 2028.

An importer may also be a packaging producer under EPR.

A GB deforestation due diligence regime is proposed but not yet law.

Not directly, but a UK group can be caught through EU subsidiaries above the CSRD thresholds, and a non-EU parent with EU turnover above €450 million in each of the last two years and an EU subsidiary or branch above €200 million is within the third-country provisions of Article 40a.

No. TNFD is a voluntary framework and no UK instrument requires it; the government’s 2023 Green Finance Strategy committed only to explore how it should be incorporated.

No. The government consulted on transition plan requirements from June to September 2025 and had published no outcome as at 11 October 2026.

Listed companies must say whether they have published a plan from 2027, but the FCA does not require one.

No. HM Treasury decided on 15 July 2025 that work to develop a UK taxonomy should not proceed.

The Companies Act duties apply to companies incorporated under it, and a company incorporated in a Crown Dependency or Gibraltar is not such a company.

The FCA’s listing rules work by listing category, so a Crown Dependency company with a UK listing in scope is caught by them.

The FCA’s UK SRS rules apply from 2027; the Modernising corporate reporting consultation, closing 30 November 2026, proposes replacing several narrative duties with baseline disclosures; the climate disclosure regulations are under review to spring 2027; the government has promised a consultation on SECR and ESOS; and a GB deforestation regime is expected to be legislated in 2027.