ESG reporting requirements in the UK: who must report what

Parts of it are, for particular organisations. There is no single UK "ESG report". Instead there are separate duties: SECR energy and carbon reporting for quoted companies and large unquoted companies and LLPs, climate-related financial disclosures in the strategic report for companies with more than 500 employees in listed, AIM, banking, insurance or £500 million-turnover categories, ESOS energy audits for large undertakings, modern slavery statements, gender pay gap reporting and, for FCA-authorised firms, the anti-greenwashing rule. Listed companies in five listing categories will report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

It depends on what the organisation is. Listed companies carry the heaviest load: SECR at any size, the listing-rule climate disclosures and, from periods beginning on or after 1 January 2027, UK SRS on a comply-or-explain basis. Large private companies may be caught by SECR (exceeding two of £36 million turnover, £18 million balance sheet and 250 employees), by the climate-related financial disclosure rules if they have more than 500 employees and turnover above £500 million, and by ESOS. FCA-authorised firms are subject to the anti-greenwashing rule. Commercial organisations with turnover of £36 million or more publish a modern slavery statement, and employers with 250 or more employees report their gender pay gap.

The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022, SI 2022/31. They amended sections 414C, 414CA and 414CB of the Companies Act 2006 and apply to financial years beginning on or after 6 April 2022. They require certain companies with more than 500 employees to include eight climate-related financial disclosures in the strategic report. The parallel regulations for LLPs are SI 2022/46.

Most duties already in force continue: SECR, the 2022 climate-related financial disclosure rules, ESOS Phase 4 (qualification date 31 December 2026), modern slavery statements and gender pay gap reporting. From 1 January 2027 two new regimes start. The FCA's final rules in PS26/19 require listed companies in UKLR 6, 14, 15, 16 and 22 to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after that date, with first reports in 2028. UK CBAM also commences on 1 January 2027 for importers of specified goods, with registration opening on 1 January 2028.

No. UK SRS S1 and S2 were published by the Department for Business and Trade on 25 February 2026 as voluntary standards for any entity. The FCA's final rules, published on 30 September 2026 as PS26/19, require listed companies in scope to report against them on a comply-or-explain basis: they either disclose in accordance with UK SRS or explain what they have not disclosed and why. No threshold for private companies has been proposed.

Large ones do. A private company can be within SECR, within the climate-related financial disclosure rules if it has more than 500 employees and turnover above £500 million, within ESOS, and within the modern slavery and gender pay gap duties on their own tests. What private companies do not have is any UK SRS obligation: no government document proposes a private-company threshold. The Modernising Corporate Reporting consultation, open until 30 November 2026, asks whether a "very large company" category should be created but proposes no figures.

ESG 4.3.1R in the FCA Handbook. It requires a firm to ensure that any reference to the sustainability characteristics of a product or service is consistent with those characteristics and fair, clear and not misleading. It applies to all FCA-authorised firms communicating with clients in the United Kingdom, or communicating or approving financial promotions to people in the United Kingdom, and has applied since 31 May 2024.

No. HM Treasury concluded on 15 July 2025 that work to develop a UK Taxonomy should not proceed. The government's sustainable finance work has instead centred on UK SRS, the assurance of sustainability reporting and transition plans.

Not under any UK statute aimed at sustainability disclosure: SECR, the climate-related financial disclosure rules and ESOS all use size tests that exclude most small and medium-sized businesses. In practice many SMEs are asked for emissions data by customers, by public-sector buyers applying PPN 006 carbon reduction plans to contracts above £5 million a year, or through CDP supply chain requests.