Assurance · UK position
Sustainability assurance in the UK: what is required, and which standard
Sustainability assurance is not required of any UK company, and the FCA’s final UK SRS rules of 30 September 2026 keep it that way.
What they add is transparency: from 2027 a listed company says whether it obtained assurance, and if so from whom, over what, to what level and against which standard.
That makes the choice of standard visible, and the UK has a new one: ISSA (UK) 5000, effective for periods beginning on or after 15 December 2026.
Is it required
Regime by regime, the answer is no
Each row is a regime a UK company may meet, with what it asks about assurance and the owner’s own words.
| Regime | Assurance position | Where it is stated |
|---|---|---|
| FCA listing rules (UK SRS), from 2027 | State whether assurance was obtained; no duty to obtain it, no explanation if not sought | UKLR 6.6.6R(8)(d); PS26/19 responses after ¶¶2.51 and 2.60 |
| UK SRS S1 and S2 | The standards contain no assurance requirement | GOV.UK: available for voluntary use |
| Companies Act climate disclosures | Disclosure duties only | CA 2006 s.414CB |
| SECR | No statutory requirement to assure or audit | Environmental Reporting Guidelines (2019), Ch. 1 and Ch. 2 §9 |
| UK ETS | Mandatory verification of the emissions report by a UKAS-accredited verifier | DESNZ, UK ETS: how to comply |
| Future UK SRS legislation | No plans for assurance requirements at this stage | Modernising corporate reporting ¶178 |
The FCA considered mandatory assurance and did not adopt it: it says disclosure of “whether assurance has been obtained, and the provider, scope, level and standards applied” will give investors decision-useful information (PS26/19).
It adds that it “will keep the case for mandating sustainability assurance under review”.
The government’s September 2026 consultation says it “does not have any plans to introduce new requirements for reporting companies to obtain assurance over future UK SRS reporting at this stage”.
“At this stage” is a present-tense statement, not a promise that assurance will never be required.
The UK ETS row is the one that confuses people: UK ETS verification is real and mandatory, but it is verification of a regulated emissions report, not assurance of sustainability disclosures.
UK groups with EU subsidiaries in CSRD scope face a different rule: CSRD assurance is limited assurance, and Directive (EU) 2026/470 removed the power to move it to reasonable assurance.
Listed companies from 2027
The assurance statement in the annual report
The made rule asks whether the listed company “has obtained third-party assurance over any of the climate-related financial disclosures, sustainability-related financial disclosures” and the related explanations under (7A) and (7B).
It applies for accounting periods beginning on or after 1 January 2027 to companies in UKLR 6, 14, 15, 16 and 22.
The FCA left the standards limb open: companies simply disclose the standards used, which keeps flexibility for issuers.
It also confirmed it is “not requiring explanations in the absence of assurance being sought”.
The statement stands even in a relief year: a company using the Scope 3 or climate-first relief must still meet the requirements on location, transition plans and assurance (PS26/19 ¶3.20).
It sits beside the transition-plan statement, covered on transition plans in the UK, and the comply-or-explain limbs covered on UK SRS comply or explain.
(i) The name of the third-party assurance provider.
(ii) Which disclosures were assured, and to what level — for example, reasonable or limited.
(iii) The assurance standards used.
(iv) If the assurance report is published, where it is and how to access it.
FCA PS26/19, Appendix 1, Annex C
Which standard
ISSA (UK) 5000, ISAE 3000, ISAE 3410 and ISO 14064-3
The standard names the rules the practitioner followed. The FCA asks which one was used and prescribes none.
| Standard | Issuer | What it is for | Status in September 2026 |
|---|---|---|---|
| ISSA (UK) 5000 | FRC | Limited and reasonable assurance of sustainability information | Issued 12 Nov 2025 for voluntary use; effective for periods beginning on or after 15 Dec 2026; earlier application permitted |
| ISSA 5000 | IAASB | The international text ISSA (UK) 5000 adopts | Published 12 Nov 2024; same effective date |
| ISAE (UK) 3000 | FRC | Assurance engagements other than audits or reviews | Still listed by the FRC as current; no UK withdrawal located |
| ISAE 3410 | IAASB | Assurance on greenhouse gas statements | Withdrawal takes effect from ISSA 5000's effective date (announced 8 May 2025) |
| ISO 14064-3:2019 | ISO | Verification and validation of GHG statements | Current; used with UKAS-accredited verification, as in UK ETS |
| ISO 14065:2020 | ISO | Requirements for bodies that validate and verify | Current; the accreditation basis for UK ETS verifiers |
The FRC issued ISSA (UK) 5000 on 12 November 2025 and described it as for voluntary use.
Its own trigger is self-selected: a practitioner “shall not represent compliance” with it unless the practitioner has complied (¶20), so it binds by representation, not by law.
It is written as an overarching standard, and a practitioner applying it “is not required to apply ISAE (UK) 3000” (¶11).
The UK text also differs from the international one elsewhere: it prohibits the use of internal auditors to provide direct assistance (¶42).
Internationally, the IAASB has said ISAE 3410 is withdrawn from ISSA 5000’s effective date, which is a derived date of 15 December 2026.
The UK position on ISAE (UK) 3000 for sustainability work is genuinely unsettled, so an engagement letter signed now should name the standard deliberately.
For greenhouse gas verification, ISO 14064-3 and ISO 14065 remain the ISO route, and UKAS accreditation to ISO 14065 is what UK ETS requires of verifiers.
What a conclusion means
Limited and reasonable assurance, read correctly
ISSA (UK) 5000 deals with both levels and mandates neither (¶9).
A reasonable assurance engagement reduces engagement risk to an acceptably low level and ends in an opinion that the information is prepared, in all material respects, in accordance with the criteria.
A limited assurance engagement ends in a conclusion about whether anything has come to the practitioner’s attention to suggest the information is materially misstated.
The standard makes a limited assurance report say that its procedures are less in extent and that “the level of assurance obtained … is substantially lower” than in a reasonable engagement (¶190(d)(ii)).
So a limited conclusion is never a statement that the data is correct; “nothing came to our attention” is the accurate paraphrase.
A practitioner may not move an engagement from reasonable to limited without reasonable justification (¶87).
In practice limited assurance dominates: 83% of FTSE 350 assurance engagements in 2023 were limited, according to the FRC’s market study.
| Reasonable | Limited | |
|---|---|---|
| Engagement risk | Acceptably low | Acceptable, but greater than reasonable |
| Form | Positive opinion | Double-negative conclusion |
| Wording | "is prepared, in all material respects" | "no matter(s) has come to the attention…" |
| Heading | Basis for Opinion | Basis for Conclusion |
| Required warning | — | Assurance "substantially lower" than reasonable |
The UK market
Who assures FTSE 350 disclosures, in the FRC’s figures
The FRC’s Assurance of Sustainability Reporting Market Study, published on 5 February 2025, is the only primary picture of the UK market, and it uses data from Minerva Analytics.
It found demand for sustainability assurance among FTSE 350 companies grew by 18 percentage points between 2019 and 2023, equivalent to 62 additional companies (¶¶9, 11).
Of the 59 providers it counted in 2023, 40 carried out only one or two engagements (¶12).
27% of assured FTSE 350 companies used their statutory auditor, rising to 37% in the FTSE 100 (¶15).
The study recommended a unified regulatory regime; the government chose a voluntary oversight regime instead.
ISAE 3000 dominated in 2023, which is why the move to ISSA (UK) 5000 will show up in the standards limb of the FCA statement.
Who can provide it
Oversight, independence and the register
Voluntary, opt-in
The government will "move forward with plans to establish a voluntary oversight regime", with practitioners able to opt in to a public register kept by the FRC (¶¶1.8–1.9). Registration will remain voluntary even once legislated (¶9.15).
Not open on our latest record
The FRC was tasked with an interim, non-legislative regime by mid-2026 and a register operational well ahead of the 1 January 2027 reporting year (¶¶1.13, 1.15). Our latest record, from July 2026, does not show it open.
IESSA, from 15 Dec 2026
The IESBA ethics standards apply to all sustainability assurance practitioners, whatever their background; for a public interest entity, a non-assurance service that might create a self-review threat is prohibited.
The oversight decision is in the government’s response of 30 January 2026, which also says the register is intended to satisfy the CSRD’s requirements for the subsidiary reporting exemptions (¶1.17).
ISSA (UK) 5000 ¶34 requires practitioners to comply with the IESBA Code’s sustainability provisions, or with requirements an appropriate authority judges at least as demanding.
The IESSA was released on 17 January 2025 and is effective for periods beginning on or after 15 December 2026.
The market claim that a firm can never prepare and assure the same information is too flat: the prohibition bites for public interest entity clients where the service might affect the assured information, and elsewhere the practitioner applies the Code’s conceptual framework.
A reference account of the standards is on our sister site’s UK SRS reference.
Getting ready
Preparing to be assured, whether or not you must
Decide the scope first: which disclosures, which metrics and which level, because the FCA statement will say exactly that.
Greenhouse gas figures are usually the first candidates, because they have a measurement basis the practitioner can test; see Scope 3 reporting under UK SRS and the UK emission factors.
Keep a data trail from source to disclosure, with the controls around it; UK SRS S1’s requirement to connect sustainability disclosures to the financial statements makes that trail easier to test.
Document the judgements, especially materiality, because an assurer tests the process as well as the numbers; see UK SRS materiality.
SECR figures carry no assurance duty, but the same discipline helps; see SECR requirements.
For the wider build, see the UK SRS implementation guide and the UK SRS compliance checklist.
This site does not provide assurance; independent providers do, and you can book a free 15-minute call to talk through scope and timing.
Frequently asked
Sustainability assurance — frequently asked
Is sustainability assurance mandatory in the UK?
No. No UK law or regulation requires a company to obtain assurance over its sustainability disclosures. The FCA's final UK SRS rules require listed companies to say whether they obtained assurance, not to obtain it, and the government's September 2026 consultation says it has no plans to introduce assurance requirements for UK SRS reporting at this stage. Verification of emissions reports under UK ETS is mandatory, but that is a different regime.
What must listed companies disclose about assurance?
Under UKLR 6.6.6R(8)(d), for accounting periods beginning on or after 1 January 2027, a listed company states whether or not it has obtained third-party assurance over its UK SRS disclosures. If it has, it names the provider, says which disclosures were assured and to what level, names the assurance standards used, and says where any published assurance report can be found. The FCA does not require an explanation where assurance was not sought.
What is ISSA (UK) 5000?
ISSA (UK) 5000, General Requirements for Sustainability Assurance Engagements, is the UK version of the IAASB's ISSA 5000. The FRC issued it on 12 November 2025 for voluntary use. It is effective for assurance engagements on sustainability information for periods beginning on or after 15 December 2026, with earlier application permitted. It binds a practitioner who says the engagement complied with it; it compels no company to obtain assurance.
What is the difference between ISSA 5000 and ISAE 3000?
ISAE 3000 (Revised) is the IAASB's general standard for assurance engagements other than audits or reviews of historical financial information, and it has been widely used for sustainability work. ISSA 5000 is a standard written for sustainability assurance. The IAASB has said ISAE 3000 will no longer apply to sustainability engagements after ISSA 5000's effective date. In the UK, ISSA (UK) 5000 says a practitioner applying it is not required to apply ISAE (UK) 3000, while the FRC still lists ISAE (UK) 3000 as a current standard.
Is ISAE 3410 being withdrawn?
Yes. The IAASB announced on 8 May 2025 that it had approved the withdrawal of ISAE 3410, Assurance Engagements on Greenhouse Gas Statements, and that the withdrawal takes effect from the effective date of ISSA 5000, which is for periods beginning on or after 15 December 2026.
What is the difference between limited and reasonable assurance?
Reasonable assurance reduces engagement risk to an acceptably low level and ends in a positive opinion that the information is prepared, in all material respects, in accordance with the criteria. Limited assurance involves procedures that are less in extent, and ends in a conclusion that nothing has come to the practitioner's attention to cause them to believe the information is materially misstated. ISSA (UK) 5000 requires a limited assurance report to say that the assurance obtained is substantially lower than in a reasonable assurance engagement.
Who can provide sustainability assurance in the UK?
There is no restriction in UK law. The government has decided on a voluntary oversight regime in which practitioners may opt in to a public register run by the FRC, whether or not they are auditors. The IESBA's ethics standards for sustainability assurance, effective from 15 December 2026, apply regardless of a practitioner's background. For a public interest entity client, a practitioner may not provide non-assurance services that might create a self-review threat over the information it assures.
Does SECR data need to be assured?
No. The government's environmental reporting guidelines say there is no requirement in the legislation for SECR emission and energy data to be independently assured, and no statutory requirement to have environmental information audited, while recommending assurance as best practice. The guidelines date from March 2019 and name standards that are now being withdrawn, so cite them for the negative only.
Is the FRC sustainability assurance register open?
The government's response of 30 January 2026 tasked the FRC with establishing an interim, non-legislative regime by mid-2026 and with having the register operational well ahead of the 1 January 2027 reporting year. On the latest record we hold, from July 2026, it had not opened. Registration is voluntary for practitioners.
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)
Appendix 1: UKLR 6.6.6R(8)(d); the response after ¶2.51 (disclosure of whether assurance was obtained and its provider, scope, level and standards) and after ¶2.60 (mandatory assurance kept under review).
- Financial Reporting CouncilISSA (UK) 5000 — General Requirements for Sustainability Assurance Engagements
¶¶9, 10, 11, 15, 18, 20, 34, 87, 190, 198L, 198R.
- Financial Reporting CouncilFRC takes steps to support quality and consistency in the assurance of sustainability reporting (12 November 2025)
Issued "for voluntary use".
- Financial Reporting CouncilAudit, assurance and ethics standards
Lists ISSA (UK) 5000 and ISAE (UK) 3000 as current standards.
- IAASBISSA 5000 — General Requirements for Sustainability Assurance Engagements
Published 12 November 2024; covers limited and reasonable assurance; effective for periods beginning on or after 15 December 2026.
- IAASBIAASB announces withdrawal of ISAE 3410 (8 May 2025)
Withdrawal "will take effect from the effective date of ISSA 5000".
- IESBAInternational Ethics Standards for Sustainability Assurance (IESSA)
Released 17 January 2025; effective 15 December 2026; applies to all sustainability assurance practitioners.
- Department for Business and TradeOversight regime for sustainability assurance — government response (30 January 2026)
¶¶1.8, 1.9, 1.13, 1.15, 1.17, 9.15: a voluntary, opt-in regime run by the FRC.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation document
¶178: no plans for new assurance requirements over UK SRS reporting "at this stage".
- Financial Reporting CouncilAssurance of Sustainability Reporting Market Study — Final Report (5 February 2025)
¶¶9, 11–13, 15, 17, 18: FTSE 350 assurance market figures (data from Minerva Analytics).
- DEFRA / BEISEnvironmental Reporting Guidelines, including SECR guidance (March 2019)
Ch. 1 Action iv and Ch. 2 §9: no statutory requirement to assure SECR data.
- GOV.UK (DESNZ)UK ETS for installations: how to comply
Verifiers "must be accredited by… UKAS to ISO 14065 and the Verification Regulation".
- ISOISO 14064-3:2019 — verification and validation of GHG statements
Edition 2, confirmed.
- ISOISO 14065:2020 — bodies validating and verifying environmental information
Edition 3; confirmed again in 2026.
- legislation.gov.ukCompanies Act 2006, section 414CB
Disclosure duties only; no assurance, audit or verification duty.
- EUR-LexDirective (EU) 2026/470 (Omnibus I), recital 5 and Article 1(3)
CSRD assurance is limited assurance; the reasonable-assurance empowerment was removed.