Reporting · The landscape
UK sustainability reporting: which rules apply, and where each report sits
UK sustainability reporting is not one report: a large or listed company can sit inside four or five regimes at once, each with its own legal basis, scope test and place in the annual report.
The newest layer changed on 30 September 2026, when the FCA published its final rules for UK SRS in PS26/19.
This page is the map: which regime, who it catches, where it sits, and which page on this site carries the detail.
Start here
One landscape, several regimes
The newest regime is UK SRS: the Department for Business and Trade published UK SRS S1 and S2 on 25 February 2026, the UK-endorsed version of the ISSB’s international standards.
Around it sit regimes that already bind large businesses: SECR for energy and carbon, ESOS for energy audits, the Companies Act climate-related financial disclosures, and the TCFD-aligned listing rules that UK SRS now replaces.
UK SRS does not sweep the others away; it overlays them, and for listed companies it takes the place of the TCFD rules.
Our sister site’s reference on sustainability reporting standards covers each framework in its own right, and the family’s UK SRS reference is at uksrs.org.uk.
Is the company listed, and in which UKLR category?
Is it quoted, or a large company or LLP?
Is it a large undertaking for ESOS?
Side by side
The regimes, as they stand on 30 September 2026
| Regime | What it covers | Who | Where it sits | Status |
|---|---|---|---|---|
| UK SRS S2 | Climate-related financial disclosure | Listed in UKLR 6, 14, 15, 16, 22; voluntary for anyone else | Annual financial report | Comply or explain, periods beginning on or after 1 Jan 2027 |
| UK SRS S1 | Other sustainability-related risks and opportunities | The same listed companies | Annual financial report | Relief for the first two periods, then comply or explain |
| TCFD-aligned listing rules | Climate disclosure against 11 recommendations | The same listed categories | Annual financial report | Apply to periods beginning before 1 Jan 2027; replaced after |
| Companies Act climate disclosures | Climate-related financial disclosures | Certain large companies and LLPs | Strategic report | In force; UK SRS S2 is a national framework for s.414CB(6) |
| SECR | Energy use, related emissions, an intensity ratio | Quoted companies of any size; large unquoted companies and LLPs | Directors’ report | In force for financial years beginning on or after 1 Apr 2019 |
| ESOS | Energy audits and action plans | Large undertakings: 250+ employees, or turnover over £44m and balance sheet over £38m | Notification to the Environment Agency | Phase 4 qualification date 31 Dec 2026; compliance date 5 Dec 2027 |
| CDP | Environmental disclosure questionnaire | Companies asked by investors or customers | CDP’s platform | Annual cycle; not a legal requirement |
The quickest orientation is to read down the “Who” column, and then follow the guides below for whichever rows apply.
The carbon-only view of the same landscape is on carbon reporting requirements in the UK.
Find a guide
The guides, by regime
UK SRS
UK SRS requirements
Every disclosure UK SRS S1 and S2 ask for.
UK SRS reporting guidance
Where the disclosures go, when, and the FCA’s statements.
UK SRS implementation guide
The roadmap, worked back from your first period.
UK SRS implementation checklist
Every task, its owner and its sign-off.
How to write a UK SRS S2 disclosure
Pillar by pillar, with illustrative wording.
UK SRS comply or explain
What an explanation must contain.
UK SRS board oversight
The governance pillar and the board’s duties.
UK SRS software
What a reporting system must be able to produce.
Energy and carbon
SECR requirements
What goes in the directors’ report, and who reports.
SECR thresholds
Which companies are in scope.
ESOS Phase 4
Qualification, the compliance date and the action plan.
Carbon reporting requirements
The UK’s carbon and energy duties on one map.
Frameworks and assurance
TCFD vs UK SRS
What changes when the FCA’s rules switch.
CDP reporting
The questionnaire, the cycle and the scores.
Sustainability assurance in the UK
ISSA (UK) 5000 and what the rules do not require.
The UK SRS consultation
How CP26/5 became the final rules.
The newest layer
UK SRS: the standards and the FCA’s rules
UK SRS S1 sets the general requirements for sustainability-related financial disclosure, and UK SRS S2 applies them to climate.
Any entity can use them voluntarily; what turns them into an obligation for listed companies is the FCA.
The consultation, CP26/5, closed on 20 March 2026, and the final rules in PS26/19 require companies in UKLR 6, 14, 15, 16 and 22 to report against UK SRS or explain, from periods beginning on or after 1 January 2027.
Scope 3 has a one-year relief and UK SRS S1 beyond climate a two-year relief; nothing becomes mandatory when a relief ends, it becomes comply or explain.
The consultation’s path to the final rules is on the UK SRS consultation, the requirements on UK SRS requirements, and the order of work on the UK SRS implementation guide.
What changed on 30 September 2026
- UK SRS S2 moved from proposed mandatory to comply or explain.
- Secondary listings and depositary receipts report against UK SRS too.
- Early adopters may use the transitional reliefs.
Source: FCA PS26/19 ¶1.7 and ¶3.19
From TCFD to UK SRS
What happens to TCFD reporting
Listed companies have reported climate information against the TCFD recommendations under the listing rules, and the FCA’s current rules require disclosure against all 11 recommended disclosures on a comply-or-explain basis (PS26/19 ¶2.3).
The final rules “will replace the existing TCFD aligned disclosures” (¶1.10), for accounting periods beginning on or after 1 January 2027.
In practice this is continuity rather than rupture: UK SRS S2 keeps the four pillars of governance, strategy, risk management, and metrics and targets.
The climate detail, and how to write each pillar, is on how to write a UK SRS S2 disclosure.
The established regimes
SECR and ESOS: the energy and carbon layer
SECR.
Streamlined Energy and Carbon Reporting applies to financial years beginning on or after 1 April 2019, under SI 2018/1155.
Quoted companies report under Part 7 of Schedule 7 to SI 2008/410 whatever their size; large unquoted companies report under Part 7A, and large LLPs under the LLP regulations.
It sits in the directors’ report and requires, among other things, at least one ratio expressing annual emissions against a quantifiable factor of the company’s choosing (Sch 7 Part 7).
ESOS.
The Energy Savings Opportunity Scheme requires large undertakings to assess their energy use in four-year phases.
Phase 4 runs from 6 December 2023 to 5 December 2027, with a qualification date of 31 December 2026 and a compliance date of 5 December 2027 (ESOS Regulations, reg 4).
A large undertaking employs at least 250 people, or has turnover over £44 million and a balance sheet total over £38 million, as the Environment Agency’s ESOS guidance sets out.
Both continue alongside UK SRS as separate obligations, and the detail is on SECR requirements and ESOS Phase 4.
The sister references on SECR requirements and the ESOS Phase 4 compliance guide cover the same regimes from another angle.
Who checks the numbers
Assurance: available, not required
The FRC issued ISSA (UK) 5000, its sustainability assurance standard, on 12 November 2025 for voluntary use, effective for engagements on periods beginning on or after 15 December 2026.
The FCA’s rules do not require assurance of UK SRS disclosures; they require a statement of whether it was obtained and, if so, from whom, over what, to what level and under which standards.
Separately, the government has decided on a voluntary oversight regime for sustainability assurance providers, to be operated by the FRC (government response, 30 January 2026).
Where UK assurance stands is set out on sustainability assurance in the UK.
To talk through which regimes apply to a particular company, you can book a free 15-minute call.
Frequently asked
UK sustainability reporting — frequently asked
What are the main UK sustainability reporting regimes?
Five overlap for large and listed companies: UK SRS, which listed companies in five categories report against on a comply-or-explain basis from periods beginning on or after 1 January 2027; the FCA’s TCFD-aligned listing rules, which UK SRS replaces from those periods; the Companies Act climate-related financial disclosures; Streamlined Energy and Carbon Reporting (SECR) in the directors’ report; and the Energy Savings Opportunity Scheme (ESOS) energy audits. CDP is a widely used questionnaire rather than a legal requirement.
Is UK SRS mandatory yet?
No UK SRS disclosure is mandatory. The FCA’s final rules (PS26/19, 30 September 2026) require listed companies in UKLR 6, 14, 15, 16 and 22 to report against UK SRS or explain, for accounting periods beginning on or after 1 January 2027. Every other entity may use UK SRS voluntarily.
How does UK SRS relate to TCFD?
The FCA’s final rules replace its TCFD-aligned listing rules for accounting periods beginning on or after 1 January 2027. UK SRS S2 keeps the TCFD’s four pillars of governance, strategy, risk management, and metrics and targets, and adds paragraph-level requirements. The TCFD itself disbanded in 2023.
Do SECR and UK SRS overlap?
They are separate obligations. SECR sits in the directors’ report and requires energy use, the related emissions and at least one intensity ratio. UK SRS sits in the annual financial report, typically the strategic report, and covers climate governance, strategy, risk management and metrics in full. A company in scope of both reports under each; the energy and Scope 1 and 2 data can serve both.
Does UK SRS replace the Companies Act climate disclosures?
Not formally. The government has confirmed that UK SRS S2 is a national reporting framework for section 414CB(6) of the Companies Act 2006, so a company reporting in accordance with UK SRS S2 does not need to duplicate the climate-related financial disclosures. It has said it will consider the future of those obligations.
When is the ESOS Phase 4 deadline?
The Phase 4 compliance date, by which notification of compliance is due, is 5 December 2027, and the qualification date is 31 December 2026. Phase 4 runs from 6 December 2023 to 5 December 2027 under regulation 4 of the ESOS Regulations.
Where should a company new to UK sustainability reporting start?
Work out which regimes apply. A quoted company, or a large company or LLP, checks SECR; a large undertaking checks ESOS; a company listed in UKLR 6, 14, 15, 16 or 22 plans for UK SRS from its first period beginning on or after 1 January 2027. The pages linked from this hub then set out each regime in detail.
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 (PDF)
UK SRS on comply or explain for UKLR 6, 14, 15, 16 and 22 from periods beginning on or after 1 January 2027; replaces the TCFD-aligned rules (¶1.10).
- Financial Conduct AuthorityPS26/19 landing page
First published 30 September 2026: comply or explain across UK SRS; Technical Note feedback by 28 October 2026; FCA webinar on 19 October 2026; supervisory information in the second half of 2027.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 — publication page
Published 25 February 2026, for voluntary use.
- 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 TradeGovernment response to the UK SRS exposure-draft consultation
Chapter 3: UK SRS S2 is a national reporting framework for s.414CB(6).
- legislation.gov.ukCompanies Act 2006, section 414CB
The Companies Act climate-related financial disclosure duty, and s.414CB(6) on national reporting frameworks.
- legislation.gov.ukThe Companies (Directors’ Report) and LLPs (Energy and Carbon Report) Regulations 2018 (SI 2018/1155)
The SECR regulations, in force for financial years beginning on or after 1 April 2019.
- legislation.gov.ukSI 2008/410 Schedule 7, Part 7 (SECR, quoted companies)
Quoted companies of any size; at least one emissions intensity ratio.
- legislation.gov.ukESOS Regulations 2014 (SI 2014/1643), regulation 4
Phase 4 runs 6 December 2023 to 5 December 2027; qualification date 31 December 2026; compliance date 5 December 2027.
- Environment AgencyEnergy Savings Opportunity Scheme (ESOS) guidance
The ESOS guidance hub; large undertaking test of 250 or more employees, or turnover over £44m and balance sheet over £38m.
- Financial Reporting CouncilAssurance standards, including ISSA (UK) 5000
ISSA (UK) 5000 issued 12 November 2025 for voluntary use.
- Financial Reporting CouncilISSA (UK) 5000 (PDF)
¶15: effective for engagements on periods beginning on or after 15 December 2026.
- Department for Business and TradeOversight regime for sustainability assurance — government response
30 January 2026: a voluntary, FRC-operated regime; ¶1.15 register "well ahead of the 1 January 2027 reporting year".
- CDPFramework alignment
CDP’s statement that its questionnaire has been aligned with IFRS S2 since 2024.
- Financial Conduct AuthorityCP26/5 consultation page
The consultation PS26/19 finalises.