UK sustainability reporting requirements: who must report what

As at 26 September 2026 the mandatory UK requirements are climate-related financial disclosures under Companies Act 2006 sections 414CA and 414CB (and the LLP equivalent), the FCA listing rule requiring a TCFD comply-or-explain statement, Streamlined Energy and Carbon Reporting (SECR), the Energy Savings Opportunity Scheme (ESOS), the FCA anti-greenwashing rule and SDR rules for regulated firms, FCA TCFD reporting for large asset managers and asset owners, and TCFD-aligned reporting by trustees of large occupational pension schemes. UK SRS S1 and S2 are voluntary standards; the FCA’s final rules (PS26/19, 30 September 2026) require listed companies in scope to report against them on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027. The Modernising corporate reporting consultation contains proposals only.

No new sustainability disclosure regime for companies has started in 2026; the obligations that apply are the ones already in force: CFD for companies and LLPs in scope, the TCFD listing rule, SECR and ESOS. What changed in 2026 is inside existing regimes: the ESOS Phase 4 amendments came into force on 22 July 2026, and 31 December 2026 is the Phase 4 qualification date. For FCA-regulated asset managers and asset owners, simplified product-level climate rules came into force on 25 September 2026. On 30 September 2026 the FCA published its final rules (PS26/19): listed companies in scope report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reporting in 2028.

No. UK SRS S1 and S2 were published on 25 February 2026 and are available for voluntary use by any entity. The FCA’s final rules (PS26/19, 30 September 2026) require companies listed in the UKLR 6, 14, 15, 16 and 22 categories to report against them on a comply-or-explain basis — report, or explain why not — for accounting periods beginning on or after 1 January 2027; CP26/5 had proposed making UK SRS S2 mandatory, and the final rules do not. For companies outside the listing rules, the government has said only that it will consider how UK SRS should be reflected in the Companies Act 2006.

A large private company may be caught by three regimes today. Climate-related financial disclosures apply if it has more than 500 employees and turnover above £500 million. SECR applies to an unquoted company unless it meets two or more of: turnover not more than £36 million, balance sheet total not more than £18 million, and not more than 250 employees. ESOS applies to a large undertaking, meaning at least 250 employees, or turnover above £44 million and a balance sheet total above £38 million. No government document proposes a UK SRS threshold or date for private companies.

SDR is the FCA's regime for investment products, not a corporate reporting regime. It includes four voluntary investment labels, naming and marketing rules for asset managers that use sustainability terms, and product and entity-level disclosures. Alongside it, the anti-greenwashing rule in ESG 4.3.1R has applied to every FCA-authorised firm since 31 May 2024, requiring sustainability references about products and services to be fair, clear and not misleading.

Only through EU operations. After Omnibus I (Directive (EU) 2026/470, in force 18 March 2026), an EU undertaking is in scope where it exceeds both 1,000 employees and €450 million net turnover, so an EU subsidiary of a UK group can be caught on its own numbers. A UK parent group can also be caught under Article 40a where it has more than €450 million of EU turnover in each of the last two consecutive financial years and an EU subsidiary or branch above €200 million; EFRAG states those third-country provisions apply from financial years starting on or after 1 January 2028.

Not yet. The Modernising corporate reporting consultation, which closes on 30 November 2026, proposes abolishing the directors’ report, so the location of SECR disclosures would move, but it does not propose changing who reports or what they report. It also records that DESNZ intends to consult on SECR and ESOS later in 2026. Until either consultation produces legislation, the current SECR rules apply unchanged.