UK regimes · the section hub
UK sustainability reporting: every regime, who it reaches, where it stands
UK sustainability reporting changed in 2026: the government published UK SRS in February, and on 30 September the FCA’s final rules put listed companies on a comply-or-explain basis from 2027.
Around it sit regimes that are already law — SECR, ESOS, the UK ETS, the packaging schemes — and new ones arriving, from UK CBAM to the Deposit Return Scheme.
This hub maps all of them, with a finder that starts from what your business does.
The UK reporting stack
Every UK regime on one map
| Regime | Status | Who | Next date |
|---|---|---|---|
| UK SRS S1 and S2 | Listing rule: comply or explain; otherwise voluntary | UKLR 6, 14, 15, 16, 22 | Periods from 1 January 2027 |
| SECR reporting | Law since 2019 | Quoted; large unquoted companies and LLPs | Every annual report |
| Climate-related financial disclosure | Law since 2022 | Companies Act categories, more than 500 employees | Every strategic report |
| ESOS scheme | Law since 2014 | Large undertakings and their UK groups | 5 December 2027 |
| UK ETS | Law | Installations, aircraft operators, ships | 31 March report · 30 April surrender |
| UK CBAM | Tax from 1 January 2027 | Importers of five sectors’ goods | 31 May 2028 first return |
| Climate change agreements | Voluntary relief | Eligible energy-intensive facilities | Target period 8 from 1 January 2027 |
| Plastic Packaging Tax | Tax since 2022 | Manufacturers and importers, 10 tonnes+ | 1 April 2027 changes |
| Packaging EPR | Law | Producers above £1m and 25 tonnes | 1 April 2027 data |
| Deposit Return Scheme | Law from 1 October 2027 | Drinks producers and retailers, England and NI | 1 October 2027 |
| SDR and anti-greenwashing | FCA rules | Authorised firms; asset managers | 2 December 2026 |
| Social Value Model | Procurement policy | Bidders for central government contracts | PPN 026 from 1 January 2027 |
| TNFD | Voluntary | Any company | ISSB draft, October 2026 |
Which regimes could apply to you
Start from what you do, not from the regime
Most businesses meet these regimes through an activity — importing steel, filling packaging, running a boiler, bidding for a contract — before they meet them as reporting duties.
The finder takes the activities and lists the regimes each one triggers, with that regime’s own test and its next date.
Size-led disclosure duties — SECR, the climate duty, ESOS — are worked in more detail on sustainability reporting, which places each disclosure in the annual report.
A tick is a reason to check, not a ruling: every regime has exemptions and group rules that its own page sets out.
Regime finder · tick what you do
3 regimes to check
Energy, emissions, an intensity ratio and efficiency action in the directors’ report.
Next: Every annual report
Measure total energy, audit the significant part, notify the Environment Agency.
Next: Qualification 31 December 2026 · compliance 5 December 2027
Register once imports of in-scope goods reach £50,000 or more in a 12-month period.
Next: Starts 1 January 2027 · first return 31 May 2028
A starting list, not a ruling: each regime has exemptions, group rules and definitions that its own page sets out.
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Standards
UK SRS: the new backbone
On 25 February 2026 the Department for Business and Trade published the final UK SRS S1 and S2 for voluntary use, issued by the Secretary of State for Business and Trade.
They are the UK’s versions of the ISSB’s IFRS S1 and S2 — UK SRS S2 on IFRS S2 as amended by the ISSB in December 2025.
The government consulted on the exposure drafts from June 2025, and Annex A of its consultation response maps the final differences paragraph by paragraph without giving a count.
UK SRS S1 sets general requirements across governance, strategy, risk management, and metrics and targets; UK SRS S1 covers it in full.
UK SRS S2 applies that structure to climate, with Scope 1, 2 and 3 emissions, scenario analysis and resilience information.
Three provisions are often run together: ¶20 makes the reporting entity the same as for the financial statements, ¶¶21–24 require connected information, and ¶64 requires the disclosures at the same time and for the same period as the financial statements.
The materiality test is financial: risks and opportunities that could reasonably be expected to affect the entity’s cash flows, its access to finance or cost of capital, and the phrase “enterprise value” appears in neither standard.
Regulation
The FCA’s final rules: comply or explain, five categories
The standards compel no one; whether listed companies report against them is the FCA’s decision.
The FCA consulted in CP26/5, published on 30 January 2026, proposing mandatory UK SRS S2 for three listing categories.
Its final rules, PS26/19 of 30 September 2026, went another way: comply or explain across all of UK SRS, for UKLR 6, 14, 15, 16 and 22.
They apply to accounting periods beginning on or after 1 January 2027, with first reporting in 2028, and the compliance statement sits in the annual financial report under UKLR 6.6.
One year of Scope 3 relief and two years for non-climate UK SRS S1 matters run from first application.
PS26/19 gives no company count; CP26/5 estimated around 600 listed companies would be affected, and that figure is the consultation’s estimate — the consultation paper sets out its basis.
The full reading is on UK SRS and the FCA, and UK SRS S1 and S2 compares the two standards.
Emissions
Scope 3 and the GHG Protocol
UK SRS S2 requires greenhouse gas emissions measured under the GHG Protocol Corporate Standard, in tonnes of CO₂ equivalent across all three scopes.
UK companies usually convert activity data with the government’s GHG conversion factors, published each year by DESNZ.
Scope 3 covers the fifteen value-chain categories of the Scope 3 Standard, and it is the disclosure the FCA’s one-year relief applies to; see Scope 3 under UK SRS.
Legacy and adjacent regimes
SECR, the climate duty and TCFD keep running
Streamlined Energy and Carbon Reporting has applied since 1 April 2019 through Schedule 7 Part 7A of SI 2008/410.
Its test is drafted as an exemption: an unquoted company is exempt if it meets two or more of turnover not more than £36m, balance sheet not more than £18m and not more than 250 employees.
The thresholds stayed where they were when the Companies Act size limits rose for periods beginning on or after 6 April 2025, because SECR carries its own.
A company using 40,000 kWh or less says so instead of giving the full disclosures, and the FRC enforces the reporting.
DESNZ’s evaluation of January 2026 counts about 19,900 companies and LLPs in scope, against 11,300 forecast; the SECR reporting guide covers the rules.
The TCFD was disbanded on 12 October 2023; its four pillars are the structure of UK SRS S2, and the FCA’s TCFD-aligned listing rule gives way to the UK SRS rules from 2027.
The Companies Act climate-related financial disclosure duty for large companies continues alongside, in the strategic report.
Carbon pricing, trade and packaging
The operational regimes, with their own returns
The UK ETS caps emissions from power, heavy industry and aviation, and since 1 July 2026 from ships of 5,000 gross tonnage and above.
The aviation and maritime limbs have their own monitoring plans and penalties.
UK CBAM taxes imports of aluminium, cement, fertilisers, hydrogen, and iron and steel from 1 January 2027, once a business’s imports reach £50,000 in a 12-month period.
Climate change agreements give eligible energy-intensive sites a Climate Change Levy discount for meeting targets.
Plastic Packaging Tax charges £228.82 a tonne on plastic packaging components with less than 30% recycled plastic.
Packaging EPR makes producers pay for household packaging waste, and the Deposit Return Scheme for drinks containers starts on 1 October 2027.
These are law for those they cover, but they are returns and payments rather than published disclosures.
Finance and procurement
Funds, ratings and public contracts
The FCA’s anti-greenwashing rule has applied to every authorised firm since 31 May 2024, and the SDR labels, naming rules and entity-level reports apply to asset managers; see SDR and anti-greenwashing.
Providing an ESG rating becomes a regulated activity on 29 June 2028.
Central government buyers ask for a Carbon Reduction Plan under PPN 006 on contracts above £5m a year, and weight social value under the Social Value Model; both are policy, not law on the supplier.
Emerging
Nature and transition plans, still moving
The ISSB decided in November 2025 to set nature-related disclosure requirements drawing on the TNFD framework, and in April 2026 chose the form: a draft IFRS Practice Statement, aimed for October 2026.
Any output would need UK endorsement before it entered UK SRS; TNFD covers the framework today.
On transition plans, the government consulted on implementation routes from June to September 2025 and is analysing feedback.
Under PS26/19, a listed company in UKLR 6, 16 or 22 states whether it has a climate-related transition plan and where it is; nobody is required to have one.
International context
Aligned to the ISSB, unlike the EU
UK SRS follows the ISSB baseline so UK disclosures stay comparable internationally; global sustainability standards maps who else has adopted it.
The EU’s CSRD applies double materiality — the company’s impact on people and the environment as well as the financial effect on the company — where UK SRS uses financial materiality alone.
The UK chose disclosure over classification: on 15 July 2025 HM Treasury decided that work to develop a UK taxonomy should not proceed, naming UK SRS, assurance and transition plans instead.
The FRC’s sustainability reporting FAQs set out the UK frame in one place.
Who runs what
Seven bodies, one landscape
| Body | Role |
|---|---|
| Department for Business and Trade | Publishes UK SRS; owns the Companies Act reporting framework |
| FCA | Listing rules for UK SRS; SDR; ESG ratings from 2028 |
| DESNZ | SECR, ESOS, the UK ETS, climate change agreements, conversion factors |
| HM Treasury | Green taxonomy decision; ESG ratings legislation |
| FRC | Enforces SECR reporting; ISSA (UK) 5000 for assurance |
| Environment Agency | Administers ESOS and climate change agreements; regulates the UK ETS in England |
| HMRC | UK CBAM, Plastic Packaging Tax and the Climate Change Levy |
Further reading
Commentary we have read, not relied on
These are law-firm, consultancy and vendor pieces; several predate the FCA’s final rules of 30 September 2026, and every fact on this page comes from the primary sources listed below.
KPMG on CP26/5, from TCFD to UK SRS — written on the consultation.
Hogan Lovells on the exposure drafts and Mishcon de Reya on the final standards.
Slaughter and May’s 2026 horizon scan and Taylor Wessing on UK SRS.
BDO on the 2025 company size thresholds, which did not reach SECR.
Macfarlanes on the end of the UK green taxonomy.
Vendor guides: MyCarbon, Novata, Seedling and Ecologi on SECR.
Test yourself
Six claims about UK regimes, true or false
The claims below were all on widely read pages in 2026, including earlier versions of this one.
Each answer names the provision or document that settles it.
For your own position, book a free 15-minute call with our network of specialists.
UK sustainability reporting: true or false?
515 listed companies must comply with UK SRS from 2027.
UK SRS S1 uses the phrase “enterprise value” for its materiality test.
SECR’s test is drafted as an exemption for small unquoted companies.
UK SRS disclosures are reported at the same time as the financial statements.
The ISSB is writing a nature Standard for 2027.
UK CBAM starts on 1 January 2027.
0 of 6 answered.
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Frequently asked
UK sustainability reporting, answered
What is UK sustainability reporting?
The set of UK regimes that ask companies to disclose or account for their sustainability performance: UK SRS for listed companies on comply or explain, SECR and the Companies Act climate duty in the annual report, ESOS energy assessments, and operational regimes such as the UK ETS, UK CBAM and the packaging schemes.
Is UK sustainability reporting mandatory?
Parts are law: SECR, the Companies Act climate duty, ESOS, the UK ETS and the packaging regimes bind those they cover.
UK SRS is voluntary for any entity, and the FCA’s final rules require listed companies in five categories to report against it or explain from 2027.
Who has to comply with UK SRS?
Under PS26/19, listed companies in UKLR 6, 14, 15, 16 and 22, on a comply-or-explain basis for periods beginning on or after 1 January 2027.
Closed-ended funds, OEICs, shell companies and debt, securitised-derivative and miscellaneous securities are excluded.
No private-company threshold is proposed anywhere.
How many companies does UK SRS cover?
PS26/19 gives no total.
CP26/5 estimated that around 600 listed companies would be affected by its proposals, and that figure should be read as the consultation’s estimate.
How is UK SRS different from SECR?
SECR asks for energy use, emissions, an intensity ratio and efficiency action in the directors’ report.
UK SRS asks for climate-related financial disclosures — governance, strategy, scenario analysis, risk management, all three emissions scopes and any transition plan — and, under S1, other sustainability matters.
Does UK SRS replace TCFD?
For listed companies, yes: the FCA’s new rules replace its TCFD-aligned listing rule for periods from 1 January 2027.
The TCFD itself was disbanded on 12 October 2023, and its four pillars are the structure of UK SRS S2.
Does the UK use double materiality?
No. UK SRS uses financial materiality: sustainability-related risks and opportunities that could reasonably be expected to affect the entity’s cash flows, access to finance or cost of capital.
The EU’s CSRD applies double materiality.
Does the UK have a green taxonomy?
No. HM Treasury decided on 15 July 2025 that work to develop a UK taxonomy should not proceed, and pointed to UK SRS, assurance of sustainability reporting and transition plans instead.
Which UK regimes apply to importers and manufacturers?
UK CBAM from 1 January 2027 for imports of aluminium, cement, fertilisers, hydrogen, and iron and steel above £50,000 in 12 months; Plastic Packaging Tax for manufacturers and importers of 10 tonnes or more of plastic packaging; and packaging EPR for producers above £1m turnover and 25 tonnes.
Who runs UK sustainability reporting?
The Department for Business and Trade publishes UK SRS; the FCA sets the listing rules; DESNZ owns SECR, ESOS, the UK ETS and climate change agreements, with the Environment Agency administering ESOS and CCAs; HMRC runs UK CBAM and Plastic Packaging Tax; and the FRC enforces SECR reporting and sets assurance standards.
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.
- FCAPS26/19: 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.
- FCA HandbookUKLR 6.6 — continuing obligations, annual financial report
Where the UK SRS compliance statement sits.
- DBTUK SRS S1 and UK SRS S2
Published 25 February 2026 for voluntary use.
- DBTConsultation response on the UK SRS exposure drafts (PDF)
Annex A maps the final differences from IFRS S1 and S2, without a count.
- legislation.gov.ukSI 2008/410 Schedule 7 Part 7A — SECR
The exemption at para 20B; the 40,000 kWh low-energy statement.
- DESNZIndependent evaluation of SECR
About 19,900 companies and LLPs in scope.
- legislation.gov.ukESOS Regulations 2014, regulation 4
Phase 4 qualification and compliance dates.
- HMRCCarbon Border Adjustment Mechanism: policy summary
From 1 January 2027 on five sectors’ imports.
- DESNZParticipating in the UK ETS
Who is covered and the annual cycle.
- legislation.gov.ukFinance Act 2021, Part 2 — Plastic Packaging Tax
The tax, the 30% test and the 10-tonne registration test.
- DefraExtended producer responsibility for packaging: who is affected
Producer size tests and duties.
- FCA HandbookESG sourcebook, chapter 4
The anti-greenwashing rule and the SDR labels.
- HM TreasuryUK Green Taxonomy consultation response
15 July 2025: work should not proceed.
- GHG ProtocolCorporate Standard
The method UK SRS S2 requires for greenhouse gas emissions.