The Task Force’s final report fixes four recommendations and eleven disclosures.
Independent reference · six standards, four UK regimes
Sustainability reporting standards
Choose the right sustainability reporting standards, understand your UK duties, and turn source records into a report that readers can trust.
The chain
What sustainability reporting is: from meter to filed report
Start with the question the report must answer, then build an evidence trail that another person can follow.
A carbon inventory supplies figures; the reporting standard also asks what those figures mean for the organisation, its risks and its decisions.
- 1
Collect the source records
Meter readings, fuel invoices and supplier records establish the inputs. - 2
Apply a documented method
Record the boundary, factor set and assumptions.
DESNZ conversion factors - 3
Connect figures to the story
Explain the risks, responses and targets relevant to the reporting audience. - 4
Review and publish
Keep the approval trail and state any limitations alongside the disclosure.
Read the detailed guidance and evidence
Sustainability reporting is a company writing down, in a form someone else can check, how much energy it used, what it emitted, and what that means for its money.
- Factors applied
- Totals grouped
- Written up
- Checked, if chosen
Energy starts as meter readings, invoices and fuel records.
A standard can be complied with, a framework can only be followed, and only a regulation compels.
The FCA’s Sustainability Disclosure Requirements cover investment products, and the government’s implementation update treats them as a separate strand.
The map
The six standards, on one map
The right standard starts with the reader: investors need information about financial prospects, while stakeholders also need information about impacts.
UK SRS and IFRS S1/S2 share a baseline; GRI, SASB, ESRS and TCFD have different roles rather than forming an interchangeable checklist.
Module 01 / 06
UK SRS
The UK-endorsed standards are available for voluntary use, with separate FCA rules for listed companies in scope.
Module 02 / 06
IFRS S1 and S2
The ISSB baseline covers sustainability-related financial information and climate-related disclosures.
Module 03 / 06
GRI
GRI focuses on an organisation’s significant impacts on the economy, environment and people.
Module 04 / 06
ESRS
European standards use double materiality and sit within the CSRD reporting route.
Module 05 / 06
SASB
Industry standards help identify disclosure topics and metrics relevant to particular business activities.
Module 06 / 06
TCFD
The 2017 recommendations established the four-pillar climate reporting structure carried into the ISSB baseline.
Read the detailed guidance and evidence
Published by
Global Reporting Initiative
Written for
Everyone affected
Materiality
Impacts on economy, environment, people
Status in the UK, 1 October 2026
Voluntary.
No UK instrument requires them.
The owner’s own page ↗Published by
IFRS Foundation (ISSB)
Written for
Investors, by industry
Materiality
Financial, industry-specific
Status in the UK, 1 October 2026
Voluntary.
UK SRS permits reference to them.
The owner’s own page ↗Published by
ISSB, IFRS Foundation
Written for
Investors and lenders
Materiality
Financial (single)
Status in the UK, 1 October 2026
Endorsed and adapted as UK SRS, not adopted.
The owner’s own page ↗Published by
Department for Business and Trade
Written for
Investors and lenders
Materiality
Financial (single)
Status in the UK, 1 October 2026
Voluntary for any entity.
Comply or explain for listed companies in scope from 2027.
The owner’s own page ↗Published by
European Commission
Written for
Investors and wider stakeholders
Materiality
Double: impact and financial
Status in the UK, 1 October 2026
EU law reaches qualifying EU undertakings; revised ESRS apply from FY2027, with a transitional choice for FY2026.
The owner’s own page ↗Published by
Task Force on Climate-related Financial Disclosures
Written for
Investors
Materiality
Financial, climate only
Status in the UK, 1 October 2026
A framework.
Disbanded 12 October 2023; carried by IFRS S2 and UK SRS S2.
The owner’s own page ↗Scope
Which UK regimes bind you
Company size alone cannot tell you every duty: quoted status, listing category, group structure and the reporting period matter too.
SECR and ESOS use different threshold tests, so passing one check does not settle the other.
Module 01 / 04
SECR
Quoted companies report at any size; large unquoted companies and LLPs use their own statutory conditions.
Module 02 / 04
ESOS
A large undertaking has at least 250 employees, or turnover over £44m and a balance sheet over £38m.
Module 03 / 04
Climate disclosures
The company route needs more than 500 employees and the relevant traded, banking, insurance or AIM status, or turnover over £500m.
Module 04 / 04
FCA / UK SRS
UKLR 6, 14, 15, 16 and 22 use comply or explain for periods beginning on or after 1 January 2027.
Read the detailed guidance and evidence
UK applicability depends on the legal route, entity and reporting period.
Enter your figures and the check names the provision behind each answer.
A large unquoted company is inside SECR when it exceeds at least two of three limits.
ESOS is different: exactly 250 employees qualifies, exactly £44m of turnover does not (Sch 1 ¶1).
The UK regime check · your figures
- AppliesSECRIn, as a large unquoted company: you meet at most one of the three “not more than” limits, so the exemption does not apply.SI 2008/410 Sch 7 Part 7A, ¶20B
- AppliesESOS Phase 4A large undertaking: at least 250 employees, or turnover over £44m and balance sheet over £38m. Qualification is judged on 31 December 2026; notification is due by 5 December 2027.SI 2014/1643 Sch 1 ¶1(a), ¶1A; reg 4
- Does not applyClimate-related financial disclosureNeeds more than 500 employees and either a traded, banking, insurance or AIM company, or turnover above £500m.Companies Act 2006 ss.414CA–414CB
- Does not applyFCA listing rules (UK SRS)No listing, no FCA duty. UK SRS stays voluntary for you.FCA PS26/19 ¶3.6; GOV.UK UK SRS guidance
Indicative, not advice.
Group aggregation, LLPs, overseas parents and how size carries across financial years are on each regime’s own page.
Nothing you enter leaves your browser.
Every duty
UK reporting duties, around one company
A business can have several reporting obligations at the same time, each with its own boundary and publication route.
Energy, climate risk, directors’ decisions and workforce disclosures belong in a connected reporting plan, while an EU group may also need a separate CSRD assessment.
Module 01 / 04
Energy and carbon
SECR reports energy and emissions, while ESOS assesses energy use and efficiency opportunities.
Module 02 / 04
Climate risk
Company climate disclosures and FCA listing rules are separate routes with separate scope tests.
Module 03 / 04
People and decisions
Section 172 statements, modern slavery statements and gender pay gap reporting have their own statutory conditions.
Module 04 / 04
EU group exposure
A UK parent or subsidiary should assess the relevant EU entity and group conditions rather than assume a UK exemption.
Read the detailed guidance and evidence
The UK stack
What is law, what is final, what is voluntary
A published standard tells you how to report; an applicable legal instrument tells you whether you must.
Keep a proposal separate from a made rule when preparing a board paper, implementation plan or reporting calendar.
Module 01 / 04
In law
SECR, ESOS and company climate disclosure duties apply when their statutory scope conditions are met.
Module 02 / 04
Final rules
PS26/19 contains the FCA’s final rules, applying to relevant periods beginning from 1 January 2027.
Module 03 / 04
Voluntary use
Any entity may choose UK SRS; publication of the standards does not make every private company report against them.
Module 04 / 04
Consultation
Modernising corporate reporting is a consultation, not an enacted private-company UK SRS mandate.
Read the detailed guidance and evidence
- In lawSECR, ESOS and s.414CB
All three bind when their size tests are met.
- FinalFCA rules from 1 January 2027
Comply or explain against UK SRS for listed companies in scope.
- VoluntaryUK SRS for any entity
Available for any entity that chooses to use it.
- ProposedModernising corporate reporting
A consultation closing 30 November 2026; every item is a proposal.
- Not proceedingUK green taxonomy
The government decided on 15 July 2025 not to proceed.
- No dutyClimate transition plans
The consultation closed 17 September 2025 without creating a general UK duty to have a plan.
- Not proposedA private-company threshold
No document proposes one for UK SRS, though lenders and customers may ask.
The consultation would move SECR disclosures, not change who reports or the thresholds (paragraph 149).
On UK SRS it says only that the government “will consider” the Companies Act, with no proposal, mechanism or date.
Lineage
From the TCFD to PS26/19: how the standards arrived
The climate reporting structure developed from TCFD into the ISSB baseline and then the UK-endorsed standards.
The FCA’s listing rules add the reporting obligation for relevant issuers; they are a different instrument from the standards themselves.
- 201701
TCFD establishes four pillars
Governance, strategy, risk management, and metrics and targets. - 202302
The ISSB issues IFRS S1 and S2
A global baseline for sustainability-related financial disclosures. - 25 Feb 202603
- 30 Sep 202604
The FCA publishes PS26/19
The final listing rules adopt comply or explain across UK SRS.
Read the detailed guidance and evidence
- The template
TCFD sets the structure
11 recommended disclosures
- The rules
The FCA makes its instrument
The instrument is made on 24 September, and PS26/19 follows on 30 September.
The dates
The dates ahead: what is law, and when it starts
Put qualification dates, period start dates and filing deadlines on different lines in the reporting plan.
For example, the FCA’s 2027 start describes an accounting period, while the first resulting annual reports arrive in 2028.
- 10 Nov 202601
Revised ESRS enter into force
Application is to financial years from 2027, with a transition choice for 2026. - 31 Dec 202602
ESOS qualification snapshot
Establish whether the undertaking meets the Phase 4 qualification test. - 1 Jan 202703
FCA reporting periods begin
Relevant listed companies start the first periods under the UK SRS rules. - 5 Dec 202704
- 202805
First FCA UK SRS reports
The first annual reports cover the relevant 2027 accounting periods.
Read the detailed guidance and evidence
What changed
What PS26/19 changed from the consultation
The final FCA rules adopted comply or explain across UK SRS, replacing the consultation’s proposed mandatory climate reporting approach.
A reporting team should build its checklist from the made instrument, then record reliefs and explanations separately.
Final reporting route
Read the detailed guidance and evidence
It proposed a mandatory UK SRS S2 without Scope 3.
All of UK SRS is on comply or explain.
CP26/5 proposed a mandatory UK SRS S2 excluding Scope 3.
The final rules adopt comply or explain across UK SRS (paragraphs 1.2 and 1.7), and replace the TCFD-aligned disclosures (paragraph 1.10).
Your first year
Reliefs and a first-year checklist, from the final rules
The FCA sets relief periods by accounting-period start date, rather than the day a report is published.
The climate-first relief and Scope 3 relief address different disclosures, and their use needs to be stated clearly in the annual report.
Using climate-first relief does not permit an assertion of compliance with UK SRS S1.
Read the detailed guidance and evidence
Reliefs by accounting-period start · UKLR TP 16
Both reliefs are available
Under UKLR TP 16.4R(2), if the annual report says the company relies on them.
FCA PS26/19, Appendix 1, UKLR TP 16 ↗Nothing you enter leaves your browser.
The Technical Advisory Committee wanted two years for the climate-first relief, the final standards removed the time limits, and the FCA’s rules now set them.
Using the climate-first relief means an entity “is not permitted to assert compliance with UK SRS S1” (¶73A).
Absolute gross Scope 1, 2 and 3, and the categories considered.
Say why you have not complied and what you plan.
UK SRS against IFRS
UK SRS S2 against IFRS S2: three differences
UK SRS is based on IFRS S1 and S2, with adaptations that matter when describing compliance.
Check the industry guidance, the treatment of reliefs and the financed-emissions explanation before using an IFRS compliance statement.
Module 01 / 04
Industry guidance
UK SRS S2 changes the relevant industry-guidance wording from “shall” to “may”.
Module 02 / 04
Relief time limits
UK SRS removes standard-level time limits; the FCA then sets relief periods for its own reporting route.
Module 03 / 04
Financed emissions
UK SRS S2 paragraph B59A asks for an explanation where the financed-emissions disclosures are not provided.
Module 04 / 04
Compliance statement
Do not assume that compliance with the UK-endorsed standards automatically establishes compliance with IFRS.
Read the detailed guidance and evidence
Industry guidance, ¶12, 23, 32
The entity shall.
Scope 3 relief
One-period limit.
Financed emissions
No paragraph B59A.
As issued by the ISSB.
As endorsed by the DBT.
Annex A of the government response lists every difference, and the letter to the FCA of 5 January 2026 confirms the relief limits came out.
Paragraph B59A in UK SRS S2 is the one place the UK is stricter.
Compliance with UK SRS is not automatically compliance with IFRS, as the FRC says.
The hard part
Three definitions of materiality, and who uses which
Materiality determines which information belongs in the report, so choose the lens before gathering every possible data point.
Financial materiality considers primary users’ decisions; impact materiality considers significant impacts; double materiality considers both.
Module 01 / 03
Financial materiality
UK SRS and ISSB focus on information that could influence decisions of primary users of general purpose financial reports.
Module 02 / 03
Impact materiality
GRI focuses on the organisation’s most significant impacts on the economy, environment and people.
Module 03 / 03
Double materiality
ESRS considers both impacts and sustainability matters that affect the undertaking.
Read the detailed guidance and evidence
A worked example
Reporting standards examples: one activity, two lenses
Consider a business buying electricity: the same activity can support an emissions calculation, an impact assessment and a discussion of financial exposure.
These illustrative questions explain the different lenses; they are not a complete disclosure checklist or a case study of an assessed company.
Impact lens
What environmental impacts arise from the activity, and how are significant impacts managed?
GRI 1: impact reportingFinancial lens
Could energy dependence, price exposure or climate risks affect the organisation’s financial prospects?
UK SRS S1: risks and opportunitiesRead the detailed guidance and evidence
Reporting quality
What makes a sustainability report useful to its reader
More data does not automatically make a better sustainability report: the information needs to answer the reader’s decision and faithfully represent the matter.
UK SRS S1 adds four qualities that make the information more useful: comparability, verifiability, timeliness and understandability.
UK SRS S1 paragraphs 10–15 provide the basis for these editorial review questions.
Module 01 / 04
Comparable
Can the reader understand changes between periods and the basis of comparisons with other organisations?
Module 02 / 04
Verifiable
Can a reviewer retrace the inputs, methods and supporting evidence?
Module 03 / 04
Timely
Does the information reach readers in time to inform the decisions it is intended to support?
Module 04 / 04
Understandable
Are important information, assumptions and limitations presented clearly rather than obscured in unnecessary detail?
Read the detailed guidance and evidence
The structure
The four pillars every climate standard shares
A climate report needs more than an emissions total: it must connect oversight, business choices, risk processes and performance.
The TCFD structure provides a useful way to organise these relationships, while the applicable standard determines the actual disclosure requirements.
Module 01 / 04
Governance
Who oversees climate-related risks and opportunities, and what information supports that oversight?
Module 02 / 04
Strategy
How do climate-related risks and opportunities affect the business, strategy and financial planning?
Module 03 / 04
Risk management
How are climate-related risks identified, assessed and managed within the organisation?
Module 04 / 04
Metrics and targets
Which measures and targets explain performance and progress against the relevant risks and opportunities?
Read the detailed guidance and evidence
The TCFD set out four pillars in 2017, and every climate standard since has carried them.
Its 2021 annex changed the guidance, not the eleven disclosures.
IFRS S2 is “consistent with” the recommendations, and UK SRS S2 does not require a transition plan to exist, while its scenario analysis approach scales to the entity’s exposure and resources, with a more advanced quantitative approach required in the circumstances in paragraph B17.
Energy
ESOS Phase 4: the regime most guides leave out
ESOS is an energy assessment regime, with a different purpose from publishing a sustainability report.
Start with qualification, then organise the assessment, sign-off and notification; the Phase 4 deadline is 5 December 2027.
Module 01 / 04
Qualification
The Phase 4 qualification date is 31 December 2026.
Module 02 / 04
Energy records
Build a traceable picture of the undertaking’s energy use rather than reuse a carbon total without checking coverage.
Module 03 / 04
Assessment
Follow the applicable ESOS requirements for assessing energy use and efficiency opportunities.
Module 04 / 04
Notification
Complete the applicable compliance route and notification by the Phase 4 deadline.
Read the detailed guidance and evidence
ESOS is not a reporting standard, which is why most guides leave it out.
Phase 4 runs from 6 December 2023 to 5 December 2027 (regulation 4), with qualification judged on 31 December 2026.
Part 8 sets maxima with downward discretion, and regulations 34A and 34B carry no penalty.
SI 2026/701 amended Phase 4 from 22 July 2026 without changing the thresholds.
The most ESOS can cost · Part 8, regulations 43 to 47
Failure to undertake an ESOS assessment
Maximum under the Regulations
£70,000
£50,000 fixed plus £500 for each of 40 working days (the cap is 80).
SI 2014/1643 Part 8, regulation 45 ↗Nothing you enter leaves your browser.
Emissions
What your figures must carry, and why the factor fell 26%
Report gross emissions and keep offsets separate, then explain the boundary, calculation methods and factor set.
The UK electricity factor changed between the 2025 and 2026 sets, so a lower calculated total does not necessarily mean the organisation used less energy.
Module 01 / 04
Boundary
Identify the reporting entity and activities covered before adding the emissions together.
Module 02 / 04
Gross emissions
UK SRS S2 asks for absolute gross emissions, without subtracting offsets.
Module 03 / 04
Factor set
Keep the DESNZ conversion factor vintage and method with the calculation.
Module 04 / 04
Comparisons
Explain factor changes as well as changes in activity when discussing performance.
Read the detailed guidance and evidence
DESNZ says most of the fall is grid decarbonisation.
The 2024 data year is skipped (methodology paper ¶3.8), so a year-on-year Scope 2 comparison should say the factor changed.
The 2026 set is on GOV.UK, and the minimum Scope 1 and 2 rule is in the GHG Protocol Corporate Standard.
SECR’s 40,000 kWh relief is from disclosure, not from the regime (¶20D(7)).
The burden
What reporting costs, and who must be assured
Separate the cost of preparing a report from the scope and cost of any assurance engagement.
The UK SRS and SECR routes have no general legal assurance duty, but the FCA requires information about assurance where a relevant listed company obtains it.
Module 01 / 04
Measured reporting cost
DESNZ’s evaluation reported a mean annual SECR cost of £7,100; this is a study finding, not a consultancy quote.
Module 02 / 04
Assurance scope
An engagement covers specified information and a stated level of assurance, rather than certifying the entire organisation.
Module 03 / 04
FCA disclosure
Where assurance is obtained, name the provider, the disclosures and the standards used.
Module 04 / 04
Review trail
Retain the evidence, review decisions and unresolved limitations that support the published statement.
Read the detailed guidance and evidence
The post-implementation review recommends retaining SECR, and the RPC rated it fit for purpose on 15 May 2026.
Where a listed company obtains assurance, the FCA’s rules ask it to name the provider, the disclosures and the standards.
ISSA (UK) 5000 applies from 15 December 2026, and is the UK version of the IAASB’s ISSA 5000.
ISAE 3410 is withdrawn from the same date.
The government’s oversight regime for providers is voluntary, and no register is live.
Interoperability
Which frameworks satisfy which others
Shared underlying data can support more than one reporting route, but the boundaries, materiality tests and disclosures still need to be reconciled.
A crosswalk helps identify gaps; it does not by itself establish compliance with both standards.
Module 01 / 04
TCFD to ISSB
IFRS S2 is consistent with the TCFD recommendations, while adding its own requirements.
Module 02 / 04
ISSB to UK SRS
Check the UK adaptations and the separate FCA reporting route.
Module 03 / 04
ISSB to ESRS
Interoperability guidance assists comparison; it is not a formal statement of equivalence.
Module 04 / 04
GRI alongside ISSB
Impact reporting and investor-focused financial disclosures can complement one another.
Read the detailed guidance and evidence
Guidance and the baseline
Where the guidance is written, go to the source
Use the instrument’s owner for requirements, dates and status; use commentary to understand the discussion around them.
Keep the source version and reporting period with the decision so another reviewer can retrace it.
Module 01 / 04
UK standards
DBT publishes UK SRS and the guidance on voluntary use.
Module 02 / 04
Listed companies
The FCA publishes the final listing rules and its reporting guidance.
Module 03 / 04
Energy and carbon
Legislation sets SECR and ESOS duties, while DESNZ publishes conversion factors and evaluations.
Module 04 / 04
Assurance and baseline
Read FRC assurance standards and the IFRS Foundation’s reporting standards in their current versions.
Read the detailed guidance and evidence
- UK SRSDepartment for Business and Trade
- Listing rulesFinancial Conduct Authority
- AssuranceFinancial Reporting Council
- Energy and carbonDESNZ evaluation and factors
- BaselineIFRS Foundation navigator
- ImpactGlobal Reporting Initiative
- SASB77 industries in 11 sectors
- SECRThe instrument that created it
- Climate dutySI 2022/31 as made
- FCACP26/5 landing page
- FCACP26/5 earlier landing page
- DESNZTransition plan consultation page
- UK CBAMFinance Act 2026 Part 5, from 1 January 2027
- AustraliaASX timings
- JapanJFSA timetable
- SingaporeSGX sustainability reporting
- CanadaSustainability Standards Board
- RegisterUse by jurisdiction
- IOSCOStatement on the ISSB standards
- PositionPRI on the final UK standards
- PositionIIGCC to the FCA
- PositionAbout the PRI
- CommentaryGlobal Financial Regulatory Blog
- CommentaryLexology, for asset managers
Positions and commentary are not sources for any figure on this page.
Reference index
The reference, topic by topic
This homepage explains the relationships; the individual guides work through the scope tests, disclosure requirements and practical evidence in detail.
Choose a reporting route first, then follow its linked threshold, timetable and preparation guidance.
Read the detailed guidance and evidence
The standards
UK SRS hub · What is UK SRS · UK SRS S1 · UK SRS S2 · IFRS S1 · IFRS S2 · S1 and S2 · IFRS · ISSB · ESRS explained · European standards · CSRD for UK companies · Four pillars · TCFD four pillars · UK SRS vs TCFD · TCFD · TCFD disclosures · TCFD requirements · TCFD UK requirements · Seven principles · Sustainability reporting · Reporting frameworks · Glossary
Scope and thresholds
UK SRS scope · Compliance calculator · Private companies · Overseas companies · Financial services · For boards · SMEs · Are reports mandatory? · Social housing · ESG hub · ESG pillars · ESG vs CSR · ESG governance · ESG integration
Dates and the FCA
UK SRS timeline · S1 and S2 timeline · Deadline · UK SRS in 2026 · FCA and UK SRS · FCA SDR · Legislation · UK regulation timeline
SECR and ESOS
SECR thresholds · SECR deadline · Is SECR mandatory? · SECR and UK SRS · ESOS hub · ESOS Phase 4 · ESOS energy audits · ESOS action plan · Phase 3 vs 4 · Is ESOS mandatory? · ISO 50001 and ESOS · ESOS and UK SRS
Emissions, materiality, assurance
Scope 3 under UK SRS · Scope 3 emissions · GHG Protocol · S1 materiality · Double materiality · Double materiality assessment · Scenario analysis · Transition plans · Assurance · ISSA (UK) 5000 · Nature · Certifications · B Corp
Implementation
UK SRS compliance · Gap analysis · Voluntary reporting · UK SRS FAQ · Sustainability software · Carbon software · Normative · Watershed · Consultancy · Carbon consultancy · Net zero consultancy
The sister reference
UK Sustainability Reporting Standards · UK SRS S1 and S2 · UK SRS S1 · UK SRS S2 · UK SRS thresholds · ESRS for a UK group · ESG reporting requirements · SECR · SECR exemptions · ESOS · ESOS Phase 4 requirements · ESOS compliance · ESOS penalties · ESOS vs SECR
Frequently asked
Sustainability reporting standards: frequently asked
What are sustainability reporting standards?
Sustainability reporting standards are published rulebooks that set out what an organisation discloses about sustainability matters, and how, so that one company's figures can be compared with another's. The set a UK organisation can be asked to use is small: the GRI Standards, the SASB Standards, the ISSB's IFRS S1 and S2, the EU's ESRS, the TCFD recommendations (a framework, now disbanded), and the UK's own UK SRS S1 and S2, which the Department for Business and Trade published on 25 February 2026.
They differ mainly in who they are written for — investors, or a wider set of stakeholders.
Are the UK Sustainability Reporting Standards mandatory?
No. UK SRS S1 and S2 are voluntary standards for any UK entity.
Under the FCA's final rules (PS26/19, 30 September 2026), listed companies in UKLR 6, 14, 15, 16 and 22 must report against them on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reporting in 2028.
That is comply or explain across both standards: the consultation, CP26/5, had proposed making UK SRS S2 mandatory, and the final rules do not.
Is sustainability reporting mandatory in the UK?
Parts of it are, under regulations rather than standards.
Quoted companies, and large unquoted companies and LLPs above the SECR thresholds, report energy use and emissions under SI 2008/410 Schedule 7, in force since 1 April 2019.
Organisations with at least 250 employees, or turnover above £44 million and a balance sheet above £38 million, must comply with ESOS, with Phase 4 qualification judged on 31 December 2026.
Companies with more than 500 employees that are traded, banking, insurance or AIM companies, or have turnover above £500 million, make the eight climate-related financial disclosures in Companies Act 2006 section 414CB.
None of the six sustainability reporting standards is mandatory for a UK company; listed companies in scope report against UK SRS on a comply-or-explain basis from 2027.
What are the ESG reporting requirements for UK companies?
There is no single UK ESG reporting law.
The requirements are the sum of several regimes: energy use and emissions under SECR, climate risk and governance in the strategic report under Companies Act 2006 section 414CB, four-yearly energy assessments under ESOS, and — on the social and governance side — gender pay gap reporting, modern slavery statements and the section 172 statement.
For listed companies in UKLR 6, 14, 15, 16 and 22, the FCA's final rules add comply-or-explain reporting against UK SRS from accounting periods beginning on or after 1 January 2027.
Which sustainability reporting framework should a UK company use?
It depends on who is asking.
Investors and lenders asking about financial exposure point to the ISSB standards, and in the UK to UK SRS S1 and S2.
Customers, employees and NGOs asking about impact point to GRI.
An EU parent or an EU-listed customer points to the ESRS.
No company has to choose only one: GRI and the IFRS Foundation have said their disclosures are complementary, and many large UK reports draw on both.
When does UK SRS reporting start for listed companies?
For accounting periods beginning on or after 1 January 2027, with first reporting in 2028.
The FCA's instrument was made on 24 September 2026 and comes into force on 1 January 2027.
Two reliefs apply: one year's non-disclosure of Scope 3 emissions under UK SRS S2, and two years' non-disclosure of UK SRS S1 non-climate matters.
A company using a relief states that it is doing so and need give no further explanation during the relief period.
How many companies are in scope of the FCA rules?
The Policy Statement gives no total count.
It names the categories: UKLR 6 (commercial companies), 14 (international commercial companies secondary listing), 15 (depositary receipts), 16 (non-equity and non-voting equity shares) and 22 (transition).
CP26/5, the consultation, estimated that around 600 listed companies would be affected — the consultation's estimate, not a figure in the final rules.
What is the difference between IFRS S2 and UK SRS S2?
UK SRS S2 is IFRS S2 as amended by the ISSB in December 2025, endorsed and adapted for the UK rather than adopted.
Annex A of the government's response lists every difference: references to the industry-based guidance at paragraphs 12, 23 and 32 changed from 'shall' to 'may'; the Scope 3 relief in Appendix C lost its one-period time limit; and paragraph B59A was added, requiring an entity to explain why it could not disclose financed emissions for the same period — the one place UK SRS is stricter than IFRS.
Compliance with UK SRS is not automatically compliance with the ISSB standards.
Does any UK company have to get its sustainability report assured?
UK SRS and SECR impose no general legal duty to obtain sustainability assurance.
SECR's guidance says there is no statutory requirement, section 414CB imposes disclosure duties only, and the FCA's final rules keep assurance as a disclosure: where a listed company obtains it, it names the provider, the disclosures assured and the assurance standards used.
The FRC issued ISSA (UK) 5000 on 12 November 2025, effective for periods beginning on or after 15 December 2026.
In practice many large companies obtain it anyway: 83% of FTSE 350 assurance engagements in 2023 were limited assurance, according to the FRC's market study.
Do UK companies have to use the GRI Standards?
No UK instrument requires the GRI Standards.
They are voluntary worldwide and ask an organisation to report its most significant impacts on the economy, environment and people.
A company reports to GRI because its stakeholders or a parent ask it to, not because UK law does.
What is the difference between the ISSB and the IFRS Foundation?
The IFRS Foundation is the not-for-profit body; the ISSB is the board it set up, formed on 3 November 2021, that writes IFRS S1 and S2.
The Foundation describes the ISSB as operating alongside, but independently from, the IASB, which writes the accounting standards.
UK SRS S1 and S2 are the UK's endorsed and adapted versions, not the ISSB's own text.
Is the ISSB mandatory in the UK?
No UK instrument requires the ISSB's standards as such.
The UK route runs through UK SRS, which the Department for Business and Trade published on 25 February 2026 and which is voluntary for any entity.
New or amended ISSB standards would not automatically apply in the UK, according to the FRC, and compliance with UK SRS is not automatically compliance with IFRS.
What are the seven principles of sustainability reporting?
No UK instrument cited on this page fixes a list of seven principles; the phrase comes from guides, and lists differ.
What the standards do fix are tests: UK SRS S1 paragraph 18 sets the financial materiality test, and paragraph B19 sets no quantitative threshold.
Our page on the seven principles sets out the common list and says where it comes from.
What is the Sustainability Disclosure Requirements regime, and is it company reporting?
No. The FCA's SDR and investment labels rules, made in Policy Statement PS23/16, apply to investment products and the firms that sell them.
They are separate from the company reporting rules on this page, and the government's implementation update treats them as a separate strand.
What does the modernising corporate reporting consultation change for SECR?
Nothing yet.
The consultation of 7 September 2026, which closes on 30 November 2026, proposes to abolish the directors' report, and says SECR disclosures would move because of it, with companies free to place them in the first half of the annual report.
That would change the address of the disclosure, not the duty: scope, thresholds and content are not part of the proposal.
DESNZ separately says it intends to consult on SECR and ESOS later in 2026.
Does the UK have a carbon border tax?
Yes, from 1 January 2027.
The UK carbon border adjustment mechanism is legislated in Finance Act 2026 Part 5 and starts on the same day as the FCA's rules, but it is a tax on imports, not a reporting standard, and it is separate from the EU's mechanism.
What is sustainability reporting?
Sustainability reporting is an organisation measuring and publishing its environmental, social and governance performance in a form others can check.
In the UK it runs from compulsory energy and emissions statements under SECR to voluntary reports against GRI or UK SRS.
The chain is the same each time: meter readings, conversion factors, an emissions inventory, a statement in the report and, if the company chooses, assurance.
What are the new UK sustainability reporting standards for 2026?
UK SRS S1 and S2, published by the Department for Business and Trade on 25 February 2026, are the new UK standards, and they are voluntary for any entity.
For listed companies in UKLR 6, 14, 15, 16 and 22 the FCA's final rules (PS26/19, 30 September 2026) add comply-or-explain reporting against them for accounting periods beginning on or after 1 January 2027.
The EU's revised ESRS apply from financial years beginning on or after 1 January 2027.
What changed between the FCA consultation and the final rules?
CP26/5 proposed mandatory UK SRS S2 excluding Scope 3 and only a signposting statement for UKLR 14 and 15.
The final rules in PS26/19 put all of UK SRS on comply or explain, bring UKLR 14 and 15 into reporting, and give one year's non-disclosure of Scope 3 and two years' non-disclosure of S1 non-climate matters.
Early adopters keep those reliefs (paragraph 3.19), and the new rules replace the TCFD-aligned disclosures (paragraph 1.10).
Do private companies have to follow UK SRS?
No. UK SRS is available for voluntary use by any entity, and no government document cited on this page proposes a threshold or date for private companies.
A private company can still be inside SECR, ESOS or the Companies Act climate disclosures when it meets their size tests, and a lender or customer can ask for UK SRS-style disclosures as a commercial matter.
The modernising corporate reporting consultation closes on 30 November 2026, and everything in it is a proposal.
Why did the UK electricity emissions factor fall by 26% in 2026?
The 2026 set gives 0.14396 kgCO2e per kWh for electricity consumed, against 0.19553 in the 2025 set.
DESNZ says most of the decrease is grid decarbonisation, with changes in the grid mix from 2023 to 2024 worth 16 percentage points and 2024 to 2025 worth 3.
The remaining 6 to 7 percentage points come from methodological changes, and the 2024 data year is skipped, so a year-on-year Scope 2 comparison across 2025 and 2026 should say so.
What is the difference between GRI and the ISSB standards?
GRI asks an organisation to report its most significant impacts on the economy, environment and people, for everyone affected.
The ISSB standards, IFRS S1 and S2, ask for the sustainability matters that affect an entity's financial prospects, for investors and lenders.
GRI and the IFRS Foundation describe their disclosures as complementary, and no UK instrument names GRI.
What should a listed company do first for the 2027 rules?
Confirm its listing category, because UKLR 6, 14, 15, 16 and 22 are in scope and UKLR 11, 12, 13, 17, 18 and 19 are not.
Then identify when its first accounting period starting on or after 1 January 2027 begins, decide whether to use the Scope 3 or S1 relief and say so in the annual report, and draft the transition plan, assurance and explanation statements the rules ask for.
The checklist on this page sets the steps out against the paragraphs.
Is there a single UK environmental reporting standard?
No. Environmental reporting in the UK is the sum of SECR for energy and emissions, ESOS for energy audits, the DESNZ conversion factors that turn energy into emissions, and the voluntary GHG Protocol, which requires a minimum of Scope 1 and Scope 2 reporting.
UK SRS S2 is the climate standard that sits above them for companies that choose it, or that the FCA's rules reach.
Prepare the evidence
Sustainability reporting standards: from a requirement to a reporting pack
Use this preparation sequence alongside the detailed requirements on this page.
An editorial workflow, not a statutory schedule.
- Stage 0101
Reporting purpose
Identify the audience and the decision the reporting should support.
- Stage 0202
Applicable route
Distinguish a legal duty, a contractual request and voluntary reporting.
- Stage 0303
Boundary and period
Set the reporting entity, scope and time period.
- Stage 0404
Evidence methods
Record the source data, assumptions and calculation methods.
- Stage 0505
Connected disclosure
Explain how the information connects to the other reports the organisation publishes.
- Stage 0606
Review record
Retain the approval trail and the limitations that the final report must state.
Read the applicable instrument: PS26/19: Aligning listed issuers' sustainability disclosures with international standards
A practical brief
An evidence pack, with a clear review trail
Ask for a pack that lets the next reviewer retrace the scope decision, follow the evidence and understand the limitations.
This describes a useful handover; it does not certify compliance or establish that a vendor or adviser delivers it.
Module 01 / 04
Applicability record
Write down the entity, reporting route and relevant period, including why the route applies.
Module 02 / 04
Evidence register
Attach each reported figure or statement to its source, method, version and limitations.
Module 03 / 04
Review trail
Name the preparer, reviewer, open questions and decisions taken before publication.
Module 04 / 04
Usable handover
Retain the working files and unresolved actions so the next reporting cycle can reuse the evidence.
View the preparation diagram
- Prepare01
Create the traceable pack
Keep the input records, calculation files and narrative together.
- Challenge02
Resolve questions before publication
Record the assumptions challenged and any limitations still unresolved.
- Retain03
Make the next cycle reproducible
Keep the approved version and the actions carried forward.
Continue your research
Related guides, one question at a time
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
Published 30 September 2026. Comply or explain across UK SRS for UKLR 6, 14, 15, 16 and 22 (¶1.2, ¶3.6), accounting periods from 1 January 2027 (¶3.12), the reliefs (¶3.14, ¶3.20), assurance (¶2.45).
- Financial Conduct AuthorityPS26/19 — Policy Statement (PDF), with the made instrument in Appendix 1
UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026, made 24 September 2026, in force 1 January 2027; UKLR 6.6.6R(7A), (7B), (8).
- Financial Conduct AuthorityCP26/5 — the consultation PS26/19 finalises (PDF)
Proposed mandatory UK SRS S2; the final rules did not adopt it. Annex 2 ¶43: around 600 listed companies affected — the consultation’s estimate.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance
“Available for voluntary use, by any entity that chooses to do so.”
- Department for Business and TradeUK SRS S1 — General requirements (PDF), ¶3, ¶18, ¶B19, ¶73A
The materiality test; no threshold; the price of the climate-first relief.
- Department for Business and TradeUK SRS S2 — Climate-related disclosures (PDF), ¶29(a), ¶36(c), ¶B32, ¶B59A, Appendix C
Absolute gross emissions; Scope 3 categories considered; the financed-emissions explanation.
- Department for Business and TradeExposure drafts of UK SRS: government response, Annex A and Chapter 3
209 responses; every UK difference from IFRS S1 and S2; UK SRS S2 as a national framework for s.414CB(6).
- Department for Business and TradeLetter from DBT to the FCA, 5 January 2026
The standards’ relief time limits removed; timing left to regulation or FCA rules.
- legislation.gov.ukSI 2008/410 Schedule 7, Part 7A ¶20B, ¶20D(7) (SECR, large unquoted companies)
The two-or-more exemption test at £36m, £18m and 250; the 40,000 kWh disclosure relief.
- legislation.gov.ukSI 2008/410 Schedule 7 (directors’ report content)
Part 7: quoted companies’ greenhouse gas and energy disclosures.
- legislation.gov.ukSI 2008/1911, regulation 12B (SECR for large LLPs)
- legislation.gov.ukSI 2018/1155 — the instrument that created SECR
In force 1 April 2019.
- legislation.gov.ukSI 2014/1643 Schedule 1 ¶1(a), ¶1A (ESOS large undertaking)
At least 250 employees, or turnover in excess of £44m and balance sheet in excess of £38m.
- legislation.gov.ukSI 2014/1643 regulation 4 (ESOS compliance periods)
Phase 4: 6 December 2023 to 5 December 2027; qualification 31 December 2026.
- legislation.gov.ukSI 2014/1643 Part 8 (ESOS penalties)
Regs 43–47: fixed maxima and daily penalties; regs 34A and 34B named nowhere.
- legislation.gov.ukSI 2026/701 — ESOS (Amendment) Regulations 2026
In force 22 July 2026; did not change the qualification thresholds.
- legislation.gov.ukCompanies Act 2006, section 414CB
The eight climate-related financial disclosures, s.414CB(2A); scope at s.414CA.
- legislation.gov.ukSI 2022/31 — Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022
Financial years beginning on or after 6 April 2022.
- legislation.gov.ukFinance Act 2026, Part 5 (UK carbon border adjustment mechanism)
The UK CBAM starts 1 January 2027.
- legislation.gov.ukSI 2015/1833, regulation 2 (Modern Slavery Act turnover threshold)
A single £36m turnover test — not SECR’s two-of-three.
- Department for Energy Security and Net ZeroIndependent evaluation of Streamlined Energy and Carbon Reporting, 29 January 2026
19,900 in scope against 11,300 forecast; mean ongoing cost £7,100 against £2,300 predicted; 94 hours; benefit–cost ratio 2.72.
- Department for Energy Security and Net ZeroPost-Implementation Review of the SECR Regulations 2018 (PDF)
RPC opinion “fit for purpose”, 15 May 2026.
- Department for Business, Innovation, Science and TradeModernising corporate reporting: consultation, published 7 September 2026
Closes 30 November 2026. A consultation: every proposal in it is a proposal.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation document (PDF), ¶57–58, ¶149–150, ¶154–155, ¶160, ¶178
SECR location; a possible “very large” category; “will consider” UK SRS in the Companies Act; no assurance plans at this stage.
- Financial Conduct AuthorityPS23/16: Sustainability Disclosure Requirements (SDR) and investment labels
Rules for investment products and the firms that sell them — not company reporting.
- Financial Reporting Standards Board of CanadaSustainability: the Canadian Sustainability Standards Board
The CSSB’s own standards, CSDS 1 and CSDS 2, and its active projects.
- HM GovernmentUK Green Taxonomy: consultation response, 15 July 2025
The taxonomy was not taken forward.
- Department for Energy Security and Net ZeroClimate-related transition plan requirements: implementation routes
Consultation 25 June to 17 September 2025. No UK entity is under a duty to have a transition plan.
- Financial Reporting CouncilAssurance of Sustainability Reporting Market Study, Final Report, 5 February 2025
¶11: 62 additional FTSE 350 companies assured 2019–2023; ¶18: 83% of engagements limited.
- Financial Reporting CouncilISSA (UK) 5000 — General Requirements for Sustainability Assurance Engagements
Issued 12 November 2025; ¶15 effective for periods beginning on or after 15 December 2026; ¶190(d)(ii).
- Financial Reporting CouncilUK Sustainability TAC issues final recommendations, 18 December 2024
- Financial Reporting CouncilSustainability reporting developments: frequently asked questions
New ISSB standards “would not automatically apply in the UK”.
- Department for Business and TradeOversight regime for assurance of sustainability-related financial disclosures: government response
A voluntary, opt-in regime.
- IAASBISSA 5000 — General Requirements for Sustainability Assurance Engagements
- IAASBWithdrawal of ISAE 3410 announced, May 2025
- IFRS FoundationIFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information
- IFRS FoundationIFRS S2 Climate-related Disclosures
- IFRS FoundationSASB Standards
77 industries across 11 sectors, maintained by the ISSB.
- IFRS FoundationISSB update to the CMAC and GPF, 18 June 2026 (PDF)
“Over 40 jurisdictions” — the owner’s count, dated.
- IFRS FoundationWho we are
- IFRS FoundationUse of IFRS Sustainability Disclosure Standards by jurisdiction
- IFRS FoundationTCFD — the successor owner’s account
IFRS S2 is “consistent with” the TCFD recommendations.
- GRIThe GRI Standards
- GRIGRI 1: Foundation 2021, section 2.2
“Most significant impacts on the economy, environment, and people.”
- GRIGRI and IFRS Foundation reaffirm commitment to complementary disclosures
- TCFDRecommendations of the TCFD, Final Report, June 2017 (Figure 4)
Four recommendations, eleven recommended disclosures.
- Financial Stability BoardTCFD 2021 Annex: Implementing the Recommendations
- Financial Stability Board2023 progress report on climate-related disclosures, 12 October 2023
Over 4,800 supporting organisations as of September 2023.
- European CommissionCommission adopts revised sustainability reporting standards, 3 July 2026
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — the revised ESRS
In force 10 November 2026; financial years beginning on or after 1 January 2027.
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026, Article 19a(1)
The double-materiality test.
- EUR-LexDirective (EU) 2026/470 (Omnibus I)
€450m net turnover and 1,000 employees, both, from FY2027.
- Department for Energy Security and Net ZeroGreenhouse gas reporting: conversion factors 2026
Published 11 June 2026; the full set is labelled “for all users” and there is no condensed set.
- Department for Energy Security and Net Zero2026 conversion factors: methodology paper (PDF), Table 9 and ¶3.8
Electricity generated 0.13096, T&D losses 0.01299 and consumed 0.14396 kgCO2e per kWh; the 2024 data year is skipped.
- Department for Energy Security and Net Zero2026 conversion factors: major changes (PDF), row 17
UK electricity −26%: most of it grid decarbonisation, 6–7 percentage points methodology.
- legislation.gov.ukCompanies Act 2006, section 414CZA (the section 172(1) statement)
- legislation.gov.ukSI 2017/172 — Equality Act 2010 (Gender Pay Gap Information) Regulations 2017
250 or more employees; no fine in the instrument.
- GHG ProtocolA Corporate Accounting and Reporting Standard
Requires a minimum of Scope 1 and Scope 2; amended in 2013 and 2015.
- EFRAG and IFRS FoundationESRS–ISSB Standards Interoperability Guidance, 2 May 2024 (PDF)
“Not a formal statement of equivalence.”
Updated .
Continue reading
Start with the question you have
The UK SRS timeline
Every date from publication on 25 February 2026 to the first reports under the FCA’s rules in 2028.
SECR thresholds
The two-of-three exemption test at £36m, £18m and 250 employees, read as the instrument writes it.
The European standards
The revised ESRS, in force 10 November 2026, and how they reach a UK group.