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Independent reference · six standards, four UK regimes · updated September 2026

Sustainability reporting standards

Six sustainability reporting standards a UK organisation can be asked to use. Which binds you?

01 · What it is

What sustainability reporting standards are, and are not.

A sustainability reporting standard is a published rulebook for what an organisation must disclose, and how.

A standard can be complied with. A framework can only be followed. A regulation is the one that decides.

What they are not

Reporting is the activity; disclosure is one item inside the report.

The TCFD was a framework; IFRS S2 and UK SRS S2 are standards; the Listing Rules are regulation.

Four words, one testchoose one
Each tab says what the word does, whether you can comply with it, and the UK example. Only regulations compel; the test is who can fine you.
↑
Six bodies publish the standards. None publishes the map.
Next — the six, on one rail
02 · The map

The six sustainability reporting standards, on one rail.

GRI, SASB, IFRS S1 and S2, the EU’s ESRS, the TCFD recommendations, and the UK’s own UK SRS S1 and S2.

Each body publishes a complete set and explains its own, and none of them binds a UK company by law today.

Two of the six are written for investors. Two are written for everyone. Two are the same standard, twice.

Who writes each of the six

GRI asks an organisation to report its impacts on the economy, environment and people; SASB is industry-based across 77 industries and is now maintained by the ISSB.

≠
Same company. Three definitions of material. Three different reports.
Next — materiality, in the standards’ own words
03 · The hard part

Three definitions of materiality, and who uses which.

This is what makes the six standards incompatible rather than merely differently worded.

UK SRS/ISSB apply single, financial materiality. EU CSRD/ESRS apply double materiality. GRI reports impacts.

The operative test, quoted at the provision

UK SRS S1 paragraph 18 makes information material if omitting it “could reasonably be expected to influence decisions that primary users… make”, and B19 sets no threshold.

The EU’s financial limb tracks UK SRS S1 almost word for word; the impact lens is what it adds.

🌐
The standards are global. The law carrying them is local.
Next — where the standards are actually law, with dates
04 · International

Where the global baselines are law.

Over 40 jurisdictions “have already decided to use or are taking steps to introduce ISSB Standards” — the IFRS Foundation’s own count on 18 June 2026, which was 37 the previous September.

“Decided to use” and “taking steps” are two different states, and the owner does not split them.

Every incumbent page prints 20, 30 or 36 jurisdictions, unsourced. The owner says over 40, and dates it.

Why this page dates every adoption figure

The Foundation’s May 2024 framing put the jurisdictions then engaged at nearly 55% of global GDP, and that is the only coverage figure this page will print.

Each jurisdiction publishes its own timetable, so every regulator below is linked rather than having its dates copied here second-hand.

Six standards. None of them binds a UK company by law today. Two older rules probably do.
Descend into the UK stack.
Which regime binds you, by threshold and provision — the dates that are law and the dates that are proposed — what your report must carry — and what it costs.
↓
Start with your own thresholds, and the provision behind each.
First — which UK regime binds you
05 · Scope

Which regimes bind you.

The honest answer for most UK organisations in September 2026: none of the six standards binds you, and two older rules that are not standards at all probably do.

Set your figures and the instrument reads each regime’s test as the statute writes it, naming the provision for every answer.

The UK regime checkyour figures
Indicative. Each verdict names the provision it reads; the regime pages carry the edge cases. Nothing you enter leaves your browser.

Three tests, three different shapes

SECR’s is an exemption test on two of three limbs, ESOS is either-or, and the Companies Act duty needs employees and turnover together.

Exactly £44 million does not qualify for ESOS and exactly 250 employees does, which is the kind of edge most guides round away.

☰
Mandatory, proposed, voluntary. The words are not interchangeable.
Next — the UK stack, by status
06 · The stack

The UK stack: what is law, proposed, and voluntary.

Three regimes bind today: SECR, ESOS and the Companies Act’s climate-related financial disclosure duty.

One more is proposed, one is voluntary for every entity, and the rest is not UK law at all.

Nobody must report under UK SRS today. The standards contain the machinery to be mandated, and no mandate.

Where “voluntary” actually comes from

The word appears nowhere in either standard: it is the government’s guidance that says “the standards are available for voluntary use, by any entity that chooses to do so”.

Two things commonly described as UK law are not — there is no UK green taxonomy, and no UK entity is under any duty to have a climate transition plan.

📅
Four dates are law. Four are proposals. Keep them apart.
Next — the dated rail, 2019 to 2029
07 · The dates

The dates: what is law, and what is proposed.

Every date on the rail is either in an instrument that has been made, or in a consultation paper that says “aim” and “would”.

The rail marks which is which, because that difference is the whole planning question.

Under the FCA’s proposals, investors would start receiving UK SRS-aligned reports from January 2028, not 2027.

Why the proposed dates need reading twice

The relief periods in CP26/5 are the exposure-draft versions, and none of them survives into the final standards, which removed their time limits altogether.

The sequence behind the standards is short: the ISSB formed on 3 November 2021, the exposure drafts were consulted on to 17 September 2025, and they drew 209 responses.

⚡
One regime carries a fixed penalty table. The energy one.
Next — ESOS Phase 4, the instrument not the guidance
ESOS Phase 4: the penalties, from Part 8SI 2014/1643
Fixed maxima with downward discretion, not “up to”. The daily amount runs per working day, for at most 80 — the guidance drops “working”.
08 · Energy

ESOS Phase 4: the regime most guides leave out.

ESOS is not a sustainability reporting standard and appears on none of the eighteen pages that rank for the term.

It is the UK regime with the clearest thresholds, the firmest dates and the only fixed penalty table, so it is the one a finance director should check first.

Qualification is judged on 31 December 2026. Notification is due by 5 December 2027. Both are in the regulation, not the guidance.

The penalty gap is in the regulation

Regulations 34A and 34B — the action plan and the progress updates — are named nowhere in Part 8, so no penalty exists for missing them.

On ESOS the stale source is usually the official one, so every Phase 4 citation here pairs the 2014 provision with the amending regulation.

▣
One skeleton runs through TCFD, IFRS S2 and UK SRS.
Next — the four pillars, and what S2 adds
09 · The structure

The four pillars every climate standard shares.

Governance, strategy, risk management, metrics and targets.

The TCFD set them out in 2017 as four recommendations and eleven recommended disclosures, and every climate standard since has carried them.

The IFRS Foundation’s word is “consistent with”. S2 then asks for industry metrics, carbon credits and financed emissions.

Which of the eleven carry a materiality gate

The qualifier “where such information is material” sits on strategy and metrics only; governance and risk management carry no gate.

Two things UK SRS S2 does not require, whatever the vendor pages say: a transition plan, and financially quantified scenario analysis.

CO₂
Gross, never net. Location-based. The 2004 Protocol.
Next — what your emissions report must carry, by regime
10 · Emissions

What your emissions figures must carry, regime by regime.

The same tonnes are reported differently under SECR, under UK SRS S2 and under the FCA’s proposed rules.

The differences are in the provisions, not the guidance, so choose the reporter you are and the panel names them.

Your emissions report, by regimechoose one
Provisions quoted: SI 2008/410 Sch 7 ¶¶15, 17, 20D, 20G; UK SRS S2 ¶29, ¶36, Appendix C; CP26/5 ¶1.5 and ¶4.8. Offsets are never subtracted under any of them.

The word that governs all of it is “gross”

UK SRS S2 paragraph 29(a)(i) requires “absolute gross” emissions across Scopes 1, 2 and 3, on the 2004 Greenhouse Gas Protocol Corporate Standard, with location-based Scope 2.

Paragraph B32 asks the entity to “consider all 15 categories” of Scope 3 before disclosing which it includes — consider, not report.

£
Eighteen pages rank for this term. None prices the burden.
Next — the cost, from the government’s own evaluation
11 · The burden

What the reporting actually costs.

The only UK regime with a measured cost is SECR, and the government measured it.

A mean ongoing cost of £7,100 a year against £2,300 predicted, 94 hours of internal time, and 19,900 organisations in scope against 11,300 forecast.

Your SECR year, against the DESNZ evaluationyour figures
Your cost = hours × rate + external spend. The comparators are the DESNZ evaluation’s means; the benefit–cost ratio is the evaluation’s central case.

Why the original estimate was three times out

The post-implementation review says the prediction was “divided by too large a denominator”, with 76% more companies and LLPs in scope than forecast.

No comparable figure exists for UK SRS, ESOS or assurance anywhere in the record, and this page does not invent one.

∴
Every relief has a price: a sentence you must print.
Next — the reliefs, and what using one obliges you to say
12 · The tension

The reliefs, their price, and where investors disagree.

The Technical Advisory Committee recommended extending the climate-first relief from one year to two.

The final standards did something else — they removed the time limits altogether — and the FCA’s draft rules then pinned the dates back on for listed companies.

An entity using the climate-first relief “is not permitted to assert compliance with UK SRS S1”. It may still assert compliance with S2.

What each relief costs the entity that uses it

UK SRS S1 paragraph 73A is the price: an entity using the climate-first relief is not permitted to assert compliance with S1, though it may still assert compliance with S2.

CP26/5 describes the reliefs as one and two years because it was written against the exposure drafts, and it says so at paragraph 2.19.

✓
Nobody must obtain assurance. Most of the FTSE 350 does.
Next — assurance: the duty that does not exist, and the market that does
13 · Assurance

Assurance: who must, who does.

As at August 2026 no UK entity is under any legal duty to obtain assurance over sustainability information.

SECR’s guidance says there is no statutory requirement, section 414CB imposes disclosure duties only, and CP26/5 proposes no mandatory assurance “at this time”.

83% of FTSE 350 assurance engagements in 2023 were limited assurance — a conclusion that says nothing came to the assurer’s attention.

What a limited conclusion actually says

Paragraph 190(d)(ii) of ISSA (UK) 5000 requires the report to state that the assurance obtained is “substantially lower” than in a reasonable assurance engagement.

A page that says “the data was assured as accurate” off a limited engagement has misread the document.

⇆
Report once, satisfy both: a claim with a footnote.
Next — interoperability, in the owners’ words
14 · Interoperability

Which frameworks satisfy which others.

Every vendor page asserts interoperability, and the owners are more careful.

The ESRS and the ISSB standards share a definition of financial materiality; they do not share a materiality regime.

“The definition of financial materiality in ESRS is aligned with the definition of materiality in IFRS S1.” The impact lens stays on top.

Read the fences the owners put around their own mappings

The ESRS–ISSB guidance fences itself three times as “not a formal statement of equivalence”, and maps 2023 paragraph numbers that the revised ESRS renumber.

GRI is the pair with no join at all: no UK instrument names it, and no GRI–ISSB mapping is held in this site’s record, so none is asserted here.

⚙
Build the capability, or buy the judgement. Usually both.
Next — software or consultancy, decided by four questions
15 · Implementation

Software or consultancy: which to buy first.

Software gives you a repeatable process, an audit trail and the data model the standards assume.

Consultancy gives you the judgement calls the standards leave to you — materiality, boundaries, the first Scope 3 inventory.

The standards specify no materiality threshold and no software. Both decisions are yours, and both are auditable.

Which decision is actually yours

The standards specify no materiality threshold and no software, so both choices are yours and both are auditable.

Those were the six standards, the four regimes, the dates that are law, and the price.
Now the sentence to take to your board.

No standard binds you yet. Two regulations probably do.
Start there.

16 · Who binds whom

Every regime, by threshold and provision.

The table no ranking page carries: each regime, who it reaches, the threshold as the instrument writes it, and the provision. Eighteen pages assert these thresholds; none links one to the law.

SECR · in force since 1 April 2019
Quoted companies at any size; large unquoted companies and LLPs unless two or more of: turnover ≤ £36m, balance sheet ≤ £18m, ≤ 250 employees. Relief, not exemption, at 40,000 kWh or less, if the report says so. SI 2008/410 Sch 7 Pt 7A ¶20B, ¶15, ¶20D(7).
ESOS Phase 4 · qualification 31 Dec 2026
At least 250 employees, or turnover in excess of £44m and balance sheet in excess of £38m. Notify by 5 December 2027. SI 2014/1643 Sch 1 ¶1, reg 4, as amended by SI 2026/701.
Climate-related financial disclosure · from 6 April 2022
Traded, banking, insurance and AIM companies with more than 500 employees; other companies with more than 500 employees and turnover above £500m. Eight disclosures. CA 2006 s.414CA–414CB.
FCA CP26/5 · proposed, rules from 1 Jan 2027
Commercial companies, non-equity and transition categories, UKLR 6, 16 and 22: mandatory UK SRS S2 less Scope 3; S1 and Scope 3 comply-or-explain. 515 issuers, plus 89 in categories 14 and 15 who would state which standards they follow. CP26/5 ¶4.4, ¶9.6, CBA ¶43.
UK SRS S1 and S2 · voluntary, no effective date
Any entity that chooses; nobody must. Issued 25 February 2026; the reliefs in Appendix E and Appendix C carry no time limit for a voluntary user. GOV.UK guidance; S1 ¶73A.
EU CSRD and ESRS · FYs from 1 Jan 2027
Undertakings above €450m net turnover and 1,000 employees, both. Reaches a UK group through its EU undertakings. Directive (EU) 2026/470; Delegated Act C(2026) 5010, Art 3.
Assurance · no UK duty
No entity must obtain it. ISSA (UK) 5000 is voluntary, effective for periods from 15 December 2026, and the FCA proposes only a statement of whether assurance was obtained. ISSA (UK) 5000 ¶15; CP26/5 ¶7.5.
Not law · three things pages say are
No UK green taxonomy, abandoned 15 July 2025. No duty to have a transition plan. No duty to use GRI, SASB or IFRS S1 and S2 in the UK. DBT, 15 July 2025.

Two adjacent regimes with the same £36 million figure are a drafting coincidence, not a cross-reference: the Modern Slavery Act threshold is a single turnover test and SECR’s is two-of-three. The ESG framing of the same stack is on ESG reporting requirements UK, the ESG hub, the ESG pillars and ESG vs CSR.

17 · Bring your thresholds

Read what reaches you, with someone who has.

This is an independent editorial reference, not a regulator and not a vendor. Every figure above is a provision or a government evaluation, cited to the paragraph; the regime check and the cost instrument ran on your numbers, in your browser, and nothing was stored.

Bring your thresholds. Leave knowing which regime binds you, from which date, and what it will cost.
Book a free consultation Or run the fuller UK SRS compliance calculator first — the same thresholds, with the edge cases.

A conversation starts with your turnover, balance sheet, headcount, listing category and EU footprint on the table, against the four tests above. The reference pages behind it are the UK SRS hub, UK SRS compliance and the gap analysis; who writes this site is on about, and how to reach us on contact.

Sustainability reporting standards mapped for UK organisations: six standards, four regimes, one question of which binds you
18 · What this page covers that others do not

The omissions, named.

We read the eighteen pages that rank for “sustainability reporting standards” and its neighbours before writing this one — eleven of them vendors, two Big Four hubs, a professional body, a law firm. This is what they collectively leave out.

A threshold linked to the instrument that sets itEvery page asserts thresholds; none links one to legislation.gov.uk, the FCA Handbook or a DBT paper.
Nobody
ESOS on the page at allThe UK regime with the firmest dates and the only fixed penalty table.
Nobody
The whole UK stack on one gridSECR, ESOS, s.414CB, the FCA and UK SRS together. ICAEW has four of five.
Nobody
Cost or burden evidenceNo cost figure, no hours, no impact assessment, on any of the eighteen.
Nobody
A UK scope decision toolTwo vendor tools, neither UK-first, neither covering all four tests.
Two pages
The ISSB jurisdiction count, sourced and datedPages print 20, 30 or 36; the owner says over 40 and dates it.
Nobody
UK SRS described as voluntarySeveral vendor pages imply it is mandatory. It is not, and the standards have no effective date.
Two pages
Materiality tied to which obligation uses whichDefinitions exist; one page transposes them; none maps them to duties.
Definitions only
Assurance: whether the UK requires itOne page names ISSA 5000; none says no UK duty exists.
Nobody
Interoperability as a mapping, not an assertionEveryone asserts it; nobody publishes the owners’ own fences.
Assertions
The four-pillar skeleton, TCFD to S2 to UK SRSThe one structural idea that unifies the field, missing from every page.
Nobody
A glossary on the pageESRS, NFSI, SECR, double materiality used undefined throughout.
Nobody

Read on 4 September 2026. A statement about what the pages contain, not about where they rank for you.

Reference index · keep reading

Keep reading: the reference, topic by topic.

This page is the map. The second-stage reference for every question it raises is below, grouped the way the questions arrive.

Take these

What to carry out of this page.

Six standards, none binding
GRI, SASB, IFRS S1 and S2, ESRS, TCFD, UK SRS. No UK instrument requires any of them of a UK company today.
Two regulations probably do
SECR at two-of-three above £36m, £18m and 250; ESOS at 250 or £44m and £38m. Different shapes; check both.
Voluntary means voluntary
UK SRS has no effective date, by design. The FCA has proposed a duty for listed companies; a proposal is not a rule.
2027 is the rule, 2028 the reports
Under CP26/5, rules from 1 January 2027; the first UK SRS-aligned reports reach investors from January 2028.
Three materialities
Financial for UK SRS and the ISSB; impacts for GRI; both for the EU. The same company, three different reports.
Gross, never net
Absolute gross emissions, location-based Scope 2, the 2004 Protocol, all fifteen Scope 3 categories considered. Offsets never subtracted.
The relief has a price
Climate-first reporters cannot assert compliance with UK SRS S1. Listed users of a relief must state that they used it.
The burden is measured
SECR: £7,100 a year against £2,300 predicted, 94 hours, 19,900 in scope. Nothing comparable exists for UK SRS, and this page does not invent it.
Questions · sustainability reporting standards FAQ

Sustainability reporting standards: FAQ.

What are sustainability reporting standards?
Sustainability reporting standards are published rulebooks that set out what an organisation must disclose about its environmental, social and governance performance, 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, SASB, the ISSB's IFRS S1 and S2, the EU's ESRS, the legacy TCFD recommendations, 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.
Who has to do sustainability reporting in the UK?
Four UK regimes already require it. SECR catches quoted companies and large unquoted companies and LLPs meeting two of three tests (£36m turnover, £18m balance sheet, 250 employees). The climate-related financial disclosure rules in Companies Act 2006 section 414CB catch traded, banking and insurance companies over 500 employees, AIM companies over 500 employees, and other companies over 500 employees with turnover above £500m. ESOS catches organisations with 250 or more employees, or turnover over £44m and a balance sheet over £38m. UK SRS S1 and S2 are voluntary for every entity today; the FCA has proposed making climate disclosure mandatory for in-scope listed companies from 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 reaffirmed in May 2026 that their disclosures are complementary, and most large UK reports draw on both.
What are the ESG reporting requirements for UK companies?
There is no single UK ESG reporting law. The ESG reporting requirements UK companies face are the sum of several regimes: energy use and Scope 1 and 2 emissions under SECR, climate risk and governance in the strategic report under Companies Act 2006 section 414CB, four-yearly energy audits under ESOS, and — on the social and governance side — gender pay gap reporting, modern slavery statements and the section 172 statement. UK SRS S1 and S2 sit on top of that as a voluntary, investor-facing standard the FCA has proposed to make mandatory for listed companies.
What are the UK Sustainability Reporting Standards (UK SRS)?
The UK Sustainability Reporting Standards (UK SRS) are the UK-endorsed version of the ISSB's global IFRS Sustainability Disclosure Standards. They were published by the Department for Business and Trade (DBT) on 25 February 2026 and comprise two standards: UK SRS S1 (general sustainability-related financial disclosures) and UK SRS S2 (climate-related disclosures). Together they give UK companies a single, comparable baseline for disclosing the sustainability and climate risks and opportunities that affect their cash flows, access to finance or cost of capital.
What is UK SRS S1?
UK SRS S1 sets the general requirements for disclosing material sustainability-related financial information — the risks and opportunities that could reasonably affect a company's cash flows, access to finance or cost of capital over the short, medium and long term. It mirrors IFRS S1 and applies across all sustainability topics, not only climate.
What is UK SRS S2?
UK SRS S2 is the climate-specific standard. It requires disclosure of climate-related risks and opportunities, greenhouse-gas emissions across Scopes 1, 2 and 3, scenario analysis and transition-plan information, following the four-pillar TCFD architecture of governance, strategy, risk management, and metrics and targets. It mirrors IFRS S2.
Are the UK Sustainability Reporting Standards mandatory?
Not yet. The finalised UK SRS S1 and S2 are currently available for voluntary use by any entity. The Financial Conduct Authority (FCA) consulted in CP26/5 on making climate and sustainability disclosures mandatory for UK-listed companies; the consultation closed on 20 March 2026 and a final policy statement is expected in autumn 2026. The Government is separately considering extending mandatory reporting to large companies through the Companies Act.
When do UK SRS become mandatory, and what is the deadline?
Under the FCA's CP26/5 proposals, mandatory reporting would apply to in-scope UK-listed companies (UK Listing Rules categories 6, 14, 15, 16 and 22) for accounting periods beginning on or after 1 January 2027, with the first reports published in 2028. Scope 3 emissions and certain UK SRS S1 reliefs phase in after the first reporting year.
Who must comply with UK SRS?
During the voluntary phase, any UK entity may apply UK SRS. Once the FCA finalises its rules, in-scope UK-listed companies would report mandatorily from 1 January 2027. Large private companies are expected to follow later via the Companies Act and the Government's Modernising Corporate Reporting programme. Many large companies are already subject to related regimes such as SECR and TCFD-aligned disclosures.
How do UK SRS differ from the ISSB's IFRS S1 and S2 standards?
UK SRS are based directly on IFRS S1 and S2 but make six minor UK-specific amendments — including adjustments to the effective dates and to certain transition reliefs — so the standards fit UK law and the listing rules. The technical content otherwise stays aligned with the global ISSB baseline to preserve international comparability.
How does UK SRS fit within the Government's broader sustainability policy?
UK SRS sits within the broader UK SDR framework, which includes FCA SDR investment product labels, transition plan requirements under separate consultation, and ISSA (UK) 5000 assurance standard. The approach supports the Leeds Reforms package aimed at strengthening the UK's position as a global financial centre.
How many countries globally are adopting ISSB standards?
37 jurisdictions have decided to use or are taking steps to introduce ISSB Standards as of September 2025, per the IFRS Foundation tracker — covering approximately 60% of global market capitalisation, 60% of global GDP, and over 40% of global greenhouse gas emissions.
What do investors think about the UK's Scope 3 and S1 carve-outs?
The PRI (representing $128tn AUM) has expressed concerns that these provisions risk limiting investors' access to material information and depart from most of the nearly 40 jurisdictions adopting ISSB standards. PRI recommends a phased mandatory approach rather than comply-or-explain.
How will the FCA enforce UK SRS compliance?
The FCA will set out its enforcement approach in a future Primary Market Bulletin — the standard mechanism for communicating supervisory expectations to listed companies. This will detail monitoring approaches, common challenges, and enforcement priorities.
Can voluntary adopters use the transitional reliefs?
Voluntary adopters can use the standards-level reliefs (UK SRS S1 paragraphs E3, E4, E6 and Scope 3 deferral in S2) but must adjust their compliance statements accordingly. The FCA's timing-specific reliefs in CP26/5 apply only to in-scope listed companies from 1 January 2027.
What are the implications for asset managers?
Listed asset managers must prepare for mandatory reporting from 2027 under FCA CP26/5. All managers benefit from improved standardised data from portfolio holdings. Private capital managers may face MCR Strand 2 implications for portfolio company scoping and data flows.
How does the UK approach compare internationally?
The UK follows the ISSB-aligned majority with six minor amendments to UK SRS S1 and S2. Australia has phased mandatory implementation by entity size. Japan permits SSBJ standards with FSA decision pending. The EU's CSRD/ESRS uses double materiality, broader than the ISSB baseline.
What is the role of transition plans under UK SRS?
The TPT framework has been integrated under the IFRS Foundation since 2024. FCA CP26/5 proposes referencing IFRS Educational Material (incorporating TPT elements) as guidance for companies. The FCA does not mandate transition plans but requires disclosure of whether and where published.
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, must 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, must 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 today; UK SRS is available for voluntary use, and the FCA has only proposed a duty for listed companies.
Do UK companies have to use the GRI Standards?
No UK instrument requires the GRI Standards. They are voluntary worldwide, published by a Dutch foundation, and ask an organisation to report its most significant impacts on the economy, environment and people. The closest UK hook is permissive: UK SRS S1 allows an entity to consider other standard-setters' material as a source of guidance. A company reports to GRI because its stakeholders or a parent ask it to, not because UK law does.
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, and where a requirement is not in the table there is none: the references to the Industry-based Guidance at paragraphs 12, 23 and 32 changed from 'shall' to 'may', while paragraph 37 kept 'shall'; the Scope 3 relief in Appendix C lost its one-period time limit; the GHG-methodology relief kept its limit to the first annual reporting period; 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?
No. As at August 2026 no UK entity is under a legal duty to obtain assurance over sustainability information: SECR's guidance says there is no statutory requirement, section 414CB imposes disclosure duties only, UK SRS is not itself mandatory, and CP26/5 says the FCA is not proposing mandatory assurance at this time while reserving the question. The FRC's ISSA (UK) 5000 was issued on 12 November 2025 for voluntary use and is effective for periods beginning on or after 15 December 2026. In practice most large listed companies obtain it anyway: 83% of FTSE 350 assurance engagements in 2023 were limited assurance, according to the FRC's market study.

The UK-specific questions continue on the UK SRS FAQ; the vocabulary is in the glossary; the sister site’s reference for the UK regime is UK Sustainability Reporting Standards.

The sourced record
The record · Sources

Every claim, and where it came from.

Every figure on this page is cited inline to the instrument that carries it, named to the provision.

Each entry says what kind of document it is — a statutory instrument or Act, a standard’s own text, a regulator’s consultation or evaluation, an owner statement, or a labelled secondary source.

Where a figure is proposed rather than made, moving rather than settled, or a chart label rather than published text, it says so.

  1. FCA — Sustainability Disclosure Requirements and investment labelsUK regulator, owner page. Rules for investment products and FCA-authorised firms (ESG 4), not for company reporting; cited for the boundary only.
  2. TCFD — Recommendations of the Task Force on Climate-related Financial Disclosures, Final Report, June 2017Framework, owner text. Figure 4, p. 14: four recommendations, eleven recommended disclosures; the materiality qualifier sits on strategy and metrics only. Not the December 2016 consultation draft.
  3. Global Reporting Initiative — the GRI StandardsStandard-setter, owner hub. Universal Standards GRI 1, 2 and 3 (2021) in effect from 1 January 2023; no UK instrument requires them.
  4. IFRS Foundation — SASB StandardsStandard-setter, owner page. 77 industries in 11 sectors under SICS®; maintained by the ISSB since the 2022 consolidation of the Value Reporting Foundation. The citable master; sasb.org redirects.
  5. IFRS Foundation — IFRS S1 General Requirements for Disclosure of Sustainability-related Financial InformationStandard, owner page. Effective for annual reporting periods beginning on or after 1 January 2024, early application permitted with IFRS S2.
  6. IFRS Foundation — IFRS S2 Climate-related DisclosuresStandard, owner page. Integrates the TCFD recommendations and SASB-derived industry metrics; amended December 2025 on greenhouse gas disclosures, effective 1 January 2027 — the ISSB’s amendments, not the UK’s.
  7. GOV.UK — UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2Government publication page. Published 25 February 2026, never revised; issued by the Secretary of State for Business and Trade after endorsing the ISSB baseline. Both standards are 45 pages.
  8. European Commission — Commission adopts revised sustainability reporting standards, 3 July 2026EU institution, owner announcement. Two Delegated Acts, C(2026) 5010 and C(2026) 5011, adopted 3 July 2026 and published in the Official Journal on 21 September 2026 as Delegated Regulations (EU) 2026/1563 and 2026/1560; application governed by Article 3 of 2026/1563, financial years beginning on or after 1 January 2027.
  9. Official Journal — Commission Delegated Regulation (EU) 2026/1563 (the revised ESRS), OJ L, 2026/1563, 21 September 2026EU law, as published. Art 3: in force 10 November 2026, applying to financial years beginning on or after 1 January 2027; Art 2 gives three options for FY2026 and requires the undertaking to state which it applies.
  10. UK Sustainability Reporting Standards — uksrs.org.ukSister site and the cluster’s fact record. Owns the UK-prefixed term and the hub Bible from which every entry on this page is drawn.
  11. UK SRS S1 — General requirements for disclosure of sustainability-related financial information (GOV.UK PDF)Standard, the text itself. ¶3 and ¶18 the materiality test; ¶25 the four core-content pillars; ¶55(a) SASB permissive; ¶73A the price of the climate-first relief; Appendix E with no effective-date paragraph.
  12. GRI — GRI 1: Foundation 2021Standard, the text itself. §2.2: the organisation prioritises “its most significant impacts on the economy, environment, and people”. The Standards do not use the phrase “impact materiality”.
  13. EUR-Lex — Directive 2013/34/EU, consolidated 18 March 2026 (the Accounting Directive as amended by the CSRD and Omnibus I)EU law, consolidated text. Art 19a(1): the double-materiality test in its operative words; the €450m and 1,000-employee scope as it applies from FY2027.
  14. IFRS Foundation — ISSB update to the CMAC and GPF, 18 June 2026Standard-setter, owner deck. “Over 40 jurisdictions have already decided to use or are taking steps to introduce ISSB Standards” — a moving count, dated on the page; 37 in September 2025.
  15. IFRS Foundation — Who we areStandard-setter, owner page. The ISSB “operates alongside—but independently from—the IASB”; formed 2021. The same page says “close to 40” jurisdictions, one of the owner’s own inconsistencies.
  16. Official Journal — Directive (EU) 2026/470 (Omnibus I), OJ L 470, 26 February 2026EU law, as published. In force 18 March 2026; Art 2(4)(a) the €450m AND 1,000-employee threshold; Art 3(1)(c) the wider Member-State transitional option.
  17. Financial Stability Board — 2023 progress report on climate-related disclosures, 12 October 2023International body, owner release. The TCFD’s final task; the TCFD “will be disbanded”, monitoring of adoption transferred to the IFRS Foundation from 2024; over 4,800 supporting organisations as of September 2023.
  18. ASX — timings updated for mandatory climate disclosuresExchange, owner page. Linked for the reader to take Australia’s timetable from the source; no date is copied onto this page.
  19. Japan Financial Services Agency — sustainability disclosure roadmap, 9 April 2026Regulator, owner document. Linked for the reader to take Japan’s timetable from the source; no date is copied onto this page.
  20. Singapore Exchange — sustainability reportingExchange, owner page. Linked for the reader to take Singapore’s timetable from the source; no date is copied onto this page.
  21. Canadian Sustainability Standards BoardStandard-setter, owner site. Linked for the reader to take Canada’s position from the source; no date is copied onto this page.
  22. IFRS Foundation — use of IFRS Sustainability Disclosure Standards by jurisdictionStandard-setter, owner register. The jurisdiction-by-jurisdiction profiles; the place to read any country’s adoption status rather than a vendor’s count.
  23. IOSCO — endorsement of the ISSB Standards, July 2023International securities regulators’ body, owner release. Why securities regulators cite the ISSB baseline.
  24. legislation.gov.uk — SI 2008/410 Schedule 7, Part 7A (large unquoted companies: energy and carbon report)UK statutory instrument, the provision. ¶20B(2): the two-or-more exemption test at £36m, £18m and 250; ¶20D(1)(b) transport fuel; ¶20D(7)(a) the 40,000 kWh relief; ¶20G the intensity ratio. Never amended since insertion.
  25. legislation.gov.uk — SI 2008/1911, the Limited Liability Partnerships (Accounts and Audit) Regulations 2008UK statutory instrument. Regulation 12B, inserted by SI 2018/1155 reg 10, carries SECR and the climate-disclosure duty for large LLPs through modified ss.415–419 and s.416A.
  26. legislation.gov.uk — SI 2014/1643 Schedule 1 (ESOS: large undertaking)UK statutory instrument, the provision. ¶1(a): at least 250 persons, or turnover in excess of amount A and balance sheet in excess of amount B; ¶1A: £44m and £38m. Paired with SI 2026/701 for Phase 4.
  27. legislation.gov.uk — Companies Act 2006, section 414CBUK Act, the provision. Subsection (2A)(a)–(h) the eight climate-related financial disclosures; (4A)–(4B) comply-or-explain for (e)–(h) only; (6) the national-framework route the government has confirmed UK SRS S2 satisfies. Scope at s.414CA.
  28. GOV.UK — UK Sustainability Reporting Standards: guidanceGovernment guidance, the master for voluntariness: “available for voluntary use, by any entity that chooses to do so”. Carries a stale line saying CP26/5 is open; it closed 20 March 2026.
  29. FCA — CP26/5 landing pageUK regulator, owner page. Published 30 January 2026; closed 20 March 2026; “aim to publish a Policy Statement in autumn 2026, subject to the final UK SRS”. No Policy Statement found as at 20 August 2026.
  30. legislation.gov.uk — SI 2018/1155, the Companies (Directors’ Report) and LLPs (Energy and Carbon Report) Regulations 2018UK statutory instrument, as made. Made 6 November 2018 by the Secretary of State under the affirmative procedure; in force 1 April 2019 (reg 1). The instrument that created SECR.
  31. legislation.gov.uk — SI 2026/701, the Energy Savings Opportunity Scheme (Amendment) Regulations 2026UK statutory instrument, as made. Made 23 June 2026, in force 22 July 2026 under Energy Act 2023 ss.254–263. The Phase 4 change map; it did not change the qualification thresholds and adds no offence.
  32. legislation.gov.uk — SI 2022/31, the Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022UK statutory instrument. A pure amending instrument: reg 1(2) commencement for financial years beginning on or after 6 April 2022; reg 5(2) a first review report due before 6 April 2027. The live duty is in CA 2006 ss.414CA–414CB.
  33. GOV.UK — UK Green Taxonomy: consultation response, 15 July 2025Government decision. The taxonomy was abandoned; there is no UK green taxonomy existing, forthcoming or in development.
  34. GOV.UK — DESNZ, Climate-related transition plan requirements: implementation routesGovernment consultation, 25 June to 17 September 2025. Two options consulted on; no outcome published on the latest check. No UK entity is under a legal duty to have a transition plan.
  35. legislation.gov.uk — Finance Act 2026, Part 5 (carbon border adjustment mechanism)UK Act, the provision. The UK CBAM is legislated and starts 1 January 2027.
  36. FCA — CP26/5, Aligning listed issuers’ sustainability disclosures with international standards, 30 January 2026UK regulator, consultation paper. ¶1.5 mandatory UK SRS S2 less Scope 3; ¶3.5 six excluded categories; ¶3.7 rules from 1 January 2027 (“aim”); ¶3.9 reliefs; ¶4.8; ¶7.5–7.8 assurance; ¶8.8–8.12; ¶9.6; CBA ¶43 the 515 and 89; CBA ¶77 reports from January 2028. Every date here is a proposal until a Policy Statement.
  37. DBT — letter from the Department for Business and Trade to the FCA, 5 January 2026Government correspondence, primary. “We will be removing specific time-references about when the reliefs would apply in the standards”; timing to be set by regulation or FCA rules. The reason CP26/5’s relief periods are superseded.
  38. FRC — UK Sustainability TAC issues final recommendations, 18 December 2024UK regulator, owner release. Recommendations agreed 5 December 2024 and published 18 December; the TAC recommended extending the climate-first relief from one year to two, which the final standards replaced by removing the limit.
  39. legislation.gov.uk — SI 2014/1643 regulation 4 (ESOS compliance periods)UK statutory instrument, the provision. Reg 4(2): a period beginning 6 December and ending 5 December four years later; 4(3)(b) qualification date 31 December 2026; 4(4)(b) compliance date 5 December 2027.
  40. legislation.gov.uk — SI 2014/1643 Part 8 (ESOS penalties)UK statutory instrument, the provisions. Reg 43 £5,000; reg 45 £50,000; reg 47 £50,000; daily £500 per working day to 80 working days; reg 41(2) publication. Regs 34A and 34B named nowhere in Part 8.
  41. TCFD — 2021 Annex: Implementing the Recommendations, October 2021Framework, owner text. §A.1: the Task Force “has not modified” the four recommendations or the eleven disclosures; guidance updated to ask for GHG emissions independent of a materiality assessment. Trailing digit -4 is the Annex, -2 the metrics guidance.
  42. IFRS Foundation — TCFDStandard-setter, successor owner’s account. TCFD “disbanded in October 2023”; IFRS S2 is “consistent with” the four recommendations and eleven disclosures, with additional requirements for industry metrics, carbon credits and financed emissions. Its establishment date for the TCFD is wrong; the FSB’s is December 2015.
  43. UK SRS S2 — Climate-related disclosures (GOV.UK PDF)Standard, the text itself. ¶14(a)(iv) “any climate-related transition plan the entity has”; ¶22 and ¶B15 scenario analysis may be qualitative; ¶29(a) absolute gross Scope 1, 2 and 3 under the 2004 GHG Protocol; ¶36(c) gross beside net; ¶B32 consider all 15 categories; ¶B59A financed emissions; Appendix C reliefs.
  44. DESNZ — Independent evaluation of Streamlined Energy and Carbon Reporting, 29 January 2026Government evaluation, primary. 19,900 in scope against 11,300 predicted; mean ongoing cost £7,100 against £2,300; 94 hours; external costs for 56%; non-compliance 14–23%; £8.1bn benefits against £3.0bn costs 2019–2025; benefit–cost ratio 2.72.
  45. DESNZ — 2026 Post-Implementation Review of the SECR Regulations 2018, 26 May 2026Government review, primary; RPC opinion “fit for purpose” 15 May 2026. Retain SECR with amendments; five candidate areas for a 2026 consultation that “do not represent final decisions”; enforcement “light touch”, no dedicated civil sanction.
  46. DBT — Exposure drafts of UK Sustainability Reporting Standards: government response, 25 February 2026Government response, primary. Annex A: every difference between UK SRS and IFRS S1 and S2 (the effective date removed; relief time limits removed; SASB permissive; ¶B59A added), with no count of amendments; Chapter 3: UK SRS S2 a national framework for s.414CB(6); DESNZ to consider SECR duplication; ¶1.21 voluntary reporters may use UK SRS immediately.
  47. Principles for Responsible Investment — PRI responds to the final versions of UK SRS, 26 February 2026Investor body, position statement. Preserved from the previous version; an advocacy position, not a source for any figure.
  48. IIGCC — response to the FCA consultation, 25 March 2026Investor body, position statement. Preserved from the previous version; an advocacy position, not a source for any figure.
  49. FRC — Assurance of Sustainability Reporting Market Study, Final Report, 5 February 2025UK regulator, market study; data source Minerva Analytics. ¶11: 62 additional FTSE 350 companies assured 2019–2023, 18 percentage points; ¶12: 59 providers; ¶13: Big Four 40%; ¶17: 69% ISAE 3000; ¶18: 83% limited. The 39%/57% chart labels are not in the text and are not used.
  50. FRC — ISSA (UK) 5000, General Requirements for Sustainability Assurance Engagements, 12 November 2025Assurance standard, the text itself, issued for voluntary use. ¶15 effective for periods beginning on or after 15 December 2026, earlier application permitted; ¶20 binds by representation; ¶34 the IESBA Code; ¶190(d)(ii) limited assurance “substantially lower”.
  51. IAASB — ISSA 5000International assurance standard, owner page. Published 12 November 2024, effective for periods beginning on or after 15 December 2026; deals with both reasonable and limited engagements and mandates neither.
  52. IAASB — withdrawal of ISAE 3410 announced, 8 May 2025International standard-setter, owner announcement. ISAE 3410 withdrawn from ISSA 5000’s effective date; ISAE 3000 (Revised) remains live.
  53. DBT — Developing an oversight regime for assurance of sustainability-related financial disclosures: government response, 30 January 2026Government response, primary. 99 formal responses; a voluntary, opt-in, public register; the FRC tasked with an interim regime by mid-2026, a target passed unmet on the latest dated record (ICAEW, 14 July 2026).
  54. EFRAG and IFRS Foundation — ESRS–ISSB Standards Interoperability Guidance, 2 May 2024Standard-setters’ joint guidance, owner text. The financial-materiality definition aligned (§1.1); the impact lens retained; “not a formal statement of equivalence”; maps ESRS (2023) paragraph numbers that the 2026 revision renumbers.
  55. FRC — Sustainability reporting developments: frequently asked questions (updated 26 February 2026)UK regulator, owner FAQ. New or amended ISSB standards “would not automatically apply in the UK” but must go through endorsement; reporting against UK SRS “is not currently mandatory”. Stale on ISSB project timing; cited for the endorsement point only.
  56. uksrs.org.uk — UK SRS S1 and S2Sister site, the UK-side reference for the pair of standards. Preserved from the previous version.
  57. uksrs.org.uk — UK SRS S1Sister site, the UK-side reference for S1. Preserved from the previous version.
  58. uksrs.org.uk — UK SRS S2Sister site, the UK-side reference for S2. Preserved from the previous version.
  59. uksrs.org.uk — ESRSSister site, the UK-side reference for the European standards. Preserved from the previous version.
  60. Carbon Legal — carbon compliance consultancySister site, a consultancy. A service link, not a source for any figure; preserved from the previous version.
  61. Fractional Quest — fractional sustainability expertsSister site, an advisory service. A service link, not a source; preserved from the previous version.
  62. GTM Quest — go-to-market consultingSister site, a consultancy. A service link, not a source; preserved from the previous version.
  63. GTM Quest — the guide to GTM consultantsSister site, a guide. A service link, not a source; preserved from the previous version.
  64. legislation.gov.uk — SI 2015/1833, the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015UK statutory instrument, as made. Reg 2: the £36 million turnover threshold, a single test including subsidiaries (reg 3) — a drafting coincidence with SECR’s figure, not a cross-reference.

Carried over, so no citation is lost

The site’s fact record, from which every entry is drawn, is the cluster’s reference at uksrs.org.uk.

No standard binds you yet. Two regulations probably do. Start there.
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