Sustainability reporting standards
Six sustainability reporting standards a UK organisation can be asked to use. Which binds you?
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
No standard binds you yet. Two regulations probably do.
Start there.
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.
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.
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.
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.
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.
Read on 4 September 2026. A statement about what the pages contain, not about where they rank for you.
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.
What to carry out of this page.
Sustainability reporting standards: FAQ.
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.
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.
- FCA — Sustainability Disclosure Requirements and investment labels
- TCFD — Recommendations of the Task Force on Climate-related Financial Disclosures, Final Report, June 2017
- Global Reporting Initiative — the GRI Standards
- IFRS Foundation — SASB Standards
- IFRS Foundation — IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information
- IFRS Foundation — IFRS S2 Climate-related Disclosures
- GOV.UK — UK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
- European Commission — Commission adopts revised sustainability reporting standards, 3 July 2026
- Official Journal — Commission Delegated Regulation (EU) 2026/1563 (the revised ESRS), OJ L, 2026/1563, 21 September 2026
- UK Sustainability Reporting Standards — uksrs.org.uk
- UK SRS S1 — General requirements for disclosure of sustainability-related financial information (GOV.UK PDF)
- GRI — GRI 1: Foundation 2021
- EUR-Lex — Directive 2013/34/EU, consolidated 18 March 2026 (the Accounting Directive as amended by the CSRD and Omnibus I)
- IFRS Foundation — ISSB update to the CMAC and GPF, 18 June 2026
- IFRS Foundation — Who we are
- Official Journal — Directive (EU) 2026/470 (Omnibus I), OJ L 470, 26 February 2026
- Financial Stability Board — 2023 progress report on climate-related disclosures, 12 October 2023
- ASX — timings updated for mandatory climate disclosures
- Japan Financial Services Agency — sustainability disclosure roadmap, 9 April 2026
- Singapore Exchange — sustainability reporting
- Canadian Sustainability Standards Board
- IFRS Foundation — use of IFRS Sustainability Disclosure Standards by jurisdiction
- IOSCO — endorsement of the ISSB Standards, July 2023
- legislation.gov.uk — SI 2008/410 Schedule 7, Part 7A (large unquoted companies: energy and carbon report)
- legislation.gov.uk — SI 2008/1911, the Limited Liability Partnerships (Accounts and Audit) Regulations 2008
- legislation.gov.uk — SI 2014/1643 Schedule 1 (ESOS: large undertaking)
- legislation.gov.uk — Companies Act 2006, section 414CB
- GOV.UK — UK Sustainability Reporting Standards: guidance
- FCA — CP26/5 landing page
- legislation.gov.uk — SI 2018/1155, the Companies (Directors’ Report) and LLPs (Energy and Carbon Report) Regulations 2018
- legislation.gov.uk — SI 2026/701, the Energy Savings Opportunity Scheme (Amendment) Regulations 2026
- legislation.gov.uk — SI 2022/31, the Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022
- GOV.UK — UK Green Taxonomy: consultation response, 15 July 2025
- GOV.UK — DESNZ, Climate-related transition plan requirements: implementation routes
- legislation.gov.uk — Finance Act 2026, Part 5 (carbon border adjustment mechanism)
- FCA — CP26/5, Aligning listed issuers’ sustainability disclosures with international standards, 30 January 2026
- DBT — letter from the Department for Business and Trade to the FCA, 5 January 2026
- FRC — UK Sustainability TAC issues final recommendations, 18 December 2024
- legislation.gov.uk — SI 2014/1643 regulation 4 (ESOS compliance periods)
- legislation.gov.uk — SI 2014/1643 Part 8 (ESOS penalties)
- TCFD — 2021 Annex: Implementing the Recommendations, October 2021
- IFRS Foundation — TCFD
- UK SRS S2 — Climate-related disclosures (GOV.UK PDF)
- DESNZ — Independent evaluation of Streamlined Energy and Carbon Reporting, 29 January 2026
- DESNZ — 2026 Post-Implementation Review of the SECR Regulations 2018, 26 May 2026
- DBT — Exposure drafts of UK Sustainability Reporting Standards: government response, 25 February 2026
- Principles for Responsible Investment — PRI responds to the final versions of UK SRS, 26 February 2026
- IIGCC — response to the FCA consultation, 25 March 2026
- FRC — Assurance of Sustainability Reporting Market Study, Final Report, 5 February 2025
- FRC — ISSA (UK) 5000, General Requirements for Sustainability Assurance Engagements, 12 November 2025
- IAASB — ISSA 5000
- IAASB — withdrawal of ISAE 3410 announced, 8 May 2025
- DBT — Developing an oversight regime for assurance of sustainability-related financial disclosures: government response, 30 January 2026
- EFRAG and IFRS Foundation — ESRS–ISSB Standards Interoperability Guidance, 2 May 2024
- FRC — Sustainability reporting developments: frequently asked questions (updated 26 February 2026)
- uksrs.org.uk — UK SRS S1 and S2
- uksrs.org.uk — UK SRS S1
- uksrs.org.uk — UK SRS S2
- uksrs.org.uk — ESRS
- Carbon Legal — carbon compliance consultancy
- Fractional Quest — fractional sustainability experts
- GTM Quest — go-to-market consulting
- GTM Quest — the guide to GTM consultants
- legislation.gov.uk — SI 2015/1833, the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015
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.