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    ESG reporting requirements in the UK: which rules apply to your company in 2026 and 2027

    UK ESG reporting requirements depend on size and listing. Large companies report energy and carbon under SECR. Firms with over 500 employees and £500m turnover make climate disclosures. Listed companies move to UK SRS from 2027. ESOS, modern slavery statements, gender pay gap reporting and PPN 006 add further duties.

    Last updated 11 November 2026 · By Ella Sustainability Team

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    What are the ESG reporting requirements in the UK?

    The UK has no single ESG reporting law. A handful of separate rules each catch companies above a certain size, listing status or contract value, and each asks for a different slice of environmental, social or governance data. The table below lists the main mandatory regimes for UK companies in 2026, who they apply to and what they ask for. Most large private companies are caught by at least three of them, and listed groups by more.
    What are the ESG reporting requirements in the UK?
    RequirementWho it applies toWhat you reportWhere it goes
    SECR (Streamlined Energy and Carbon Reporting)Quoted companies of any size; large unquoted companies and LLPs (2 of 3: 250+ employees, £36m+ turnover, £18m+ balance sheet)Energy use, Scope 1 and 2 emissions, an intensity ratio and energy efficiency actionsAnnual report (directors' report)
    Climate-related financial disclosures (Companies Act)UK companies and LLPs with more than 500 employees and more than £500m turnover, plus listed, AIM, banking and insurance companies with more than 500 employeesEight climate disclosures (a to h) covering governance, risks and opportunities, scenario analysis, targets and KPIsStrategic report
    UK SRS under the UK Listing RulesCompanies with listed shares (commercial companies, transition, non-equity and secondary listing categories)Disclosures against UK SRS S1 and S2 on a comply or explain basis, for periods starting on or after 1 January 2027Annual financial report
    ESOS Phase 4Large undertakings: 250+ employees, or turnover above £44m and balance sheet above £38m, on 31 December 2026Energy audit or ISO 50001, notification by 5 December 2027 and an action plan by 5 December 2028Environment Agency portal
    Modern slavery statementCommercial organisations carrying on business in the UK with turnover of £36m or moreAn annual statement on steps taken to prevent modern slavery in operations and supply chainsYour website and the government registry
    Gender pay gap reportingEmployers with 250 or more employees on the snapshot date (5 April for most private employers)Six pay gap figures and an optional narrativeGovernment service and your website
    PPN 006 carbon reduction planSuppliers bidding for central government contracts above £5m a yearScope 1, Scope 2 and five Scope 3 categories, plus a net zero by 2050 commitmentPublished carbon reduction plan

    Which UK ESG regulations apply to my company?

    Start with four questions. Are any of your shares listed? How many employees does the group have? What are its turnover and balance sheet totals? Do you sell into central government or the EU? The answers map to the regimes like this. Use group figures, not just the parent company, because SECR and the climate disclosure rules both look at the group where consolidated accounts are prepared.
    Which UK ESG regulations apply to my company?
    If your company...Expect these requirements
    Has shares listed on the London Stock Exchange main marketSECR (global energy and emissions), UK Listing Rules climate reporting moving to UK SRS from 2027, plus the size-based rules below
    Has more than 500 employees and more than £500m turnoverCompanies Act climate-related financial disclosures, SECR, ESOS, modern slavery statement, gender pay gap
    Has 250+ employees or meets two of the SECR money testsSECR (UK energy and emissions) and, depending on the ESOS tests, ESOS Phase 4
    Has 250+ employeesGender pay gap reporting and very likely ESOS
    Has turnover of £36m or more and trades in the UKModern slavery statement
    Bids for central government contracts above £5m a yearPPN 006 carbon reduction plan
    Has a large EU subsidiary or significant EU turnoverPossibly CSRD, from financial year 2027 (EU subsidiaries) or 2028 (non-EU groups)

    SECR: the energy and carbon report in your annual report

    SECR has applied since April 2019. Quoted companies report global energy use and Scope 1 and 2 emissions. Large unquoted companies and LLPs report UK energy use and the Scope 1 and 2 emissions that go with it. Both need at least one intensity ratio, prior year comparatives, the methodology used and a description of energy efficiency action taken in the year. Scope 3 is voluntary. A company that used 40,000 kWh or less in the period can say so instead of making the full disclosure. One trap catches companies in 2026. The Companies Act size thresholds rose for accounting periods starting on or after 6 April 2025: a company is now medium-sized up to £54m turnover and a £27m balance sheet. The SECR thresholds did not move. They are still two of 250 employees, £36m turnover and £18m balance sheet, so some companies that are now medium-sized for accounts purposes must still publish an SECR report. Our SECR guide covers the content and calculation in detail.

    Climate-related financial disclosures and UK SRS

    Two separate climate disclosure rules apply in the UK, and the second is changing. 1. Companies Act climate-related financial disclosures. Since financial years starting on or after 6 April 2022, UK companies and LLPs with more than 500 employees and turnover above £500m, plus listed, AIM, banking and insurance companies with more than 500 employees, report eight items (a to h) in the strategic report. They cover governance, how risks and opportunities are identified and managed, principal risks, resilience under different climate scenarios, targets and the KPIs used to measure progress. The government is reviewing this regime and expects to conclude by spring 2027. 2. UK Listing Rules. The FCA's PS26/19 replaces the TCFD-aligned listing rule with UK Sustainability Reporting Standards on a comply or explain basis. It applies to accounting periods starting on or after 1 January 2027, so first reports land in 2028. Companies get one year of relief for Scope 3 and two years for wider sustainability disclosures under UK SRS S1. The FCA plans to publish more on its supervisory approach in the second half of 2027. UK SRS S1 and S2 are the UK-endorsed versions of IFRS S1 and S2. For private companies they are voluntary for now.

    ESOS Phase 4

    ESOS is an energy audit scheme, and it runs on much of the same data as SECR. An organisation qualifies for Phase 4 if, on 31 December 2026, it employs 250 or more people, or has turnover above £44m and a balance sheet above £38m. The key dates are a notification of compliance by 5 December 2027 and an action plan by 5 December 2028, with annual progress updates after that. Our ESOS guide sets out the full timeline and the 12 months of energy data you need.

    Modern slavery, gender pay gap and PPN 006

    Three more requirements sit outside the annual report but still need ESG data. Modern slavery statements apply to any commercial organisation that carries on business in the UK, supplies goods or services and has turnover of £36m or more. The statement covers the steps taken in the financial year to stop modern slavery in the business and its supply chains. Gender pay gap reporting applies to employers with 250 or more employees on the snapshot date. For most private employers that is 5 April, and the figures must be published within a year. PPN 006 applies when you bid for central government contracts above £5m a year procured under the Procurement Act 2023. You need a carbon reduction plan with Scope 1, Scope 2 and a defined set of Scope 3 categories, and a commitment to net zero by 2050.

    Does CSRD apply to UK companies?

    Only through EU operations. After the Omnibus I Directive, CSRD covers EU companies with more than 1,000 employees and turnover above €450m, which can include EU subsidiaries of UK groups, from financial year 2027. A non-EU group, including a UK parent, comes into scope from financial year 2028 if it generates more than €450m of turnover in the EU and has an EU subsidiary or branch with turnover above €200m. Companies with 1,000 or fewer employees that sit in a reporting company's value chain are protected: requests to them are capped at a voluntary standard based on VSME. Our CSRD after the Omnibus guide covers the detail.

    What is changing in UK ESG reporting?

    Expect the map to change over the next 18 months. 1. Modernising Corporate Reporting. The Department for Business and Trade published this consultation on 7 September 2026. It closes on 30 November 2026, with an outcome due by the end of May 2027. Proposals include replacing the prescriptive non-financial content of the strategic report with five baseline requirements, a new very large company category, and letting companies choose whether sustainability information sits in the strategic report or a separate section. 2. SECR and ESOS. DESNZ has said it will consult on both later in 2026, following the SECR post-implementation review published in May 2026. 3. Climate disclosures. The Companies Act CFD review is due by spring 2027 and will decide how UK SRS feeds into company law. Disclosures made by listed companies under the new Listing Rules are expected to count towards the Companies Act requirements. 4. Transition plans. The government is still considering responses to its 2025 transition plan consultation. Listed companies must already state whether they have published one under PS26/19. None of these proposals removes the need for the underlying energy, emissions and workforce data. They change where it is published and how much narrative goes around it.

    Our view: sort out applicability by entity, then collect once

    The question we hear most on calls with sustainability leads is which rules bite, and on which entity. What each framework asks for comes later. Groups that have grown through acquisition often find that two or three subsidiaries cross the SECR or modern slavery thresholds on their own, while the parent's view of the group says something different. In a recent demo, a sustainability lead at a privately owned group explained that their answer to a disclosure law changed completely depending on how entities were split, and that reporting in arrears meant next year's numbers already had to be right. The second pattern is duplication. The same buyer reported to CDP and to more than a dozen customer risk portals, each asking for the same greenhouse gas figures in a different format, all built in spreadsheets. Our advice is to map every requirement to the entity and year it applies to, then collect each data point once with a source attached and reuse it across SECR, ESOS, climate disclosures, customer questionnaires and CDP. That is the job Ella was built for. Ella is AI-native ESG reporting software, built as an agent: it sends collect links to data owners, chases missing responses, reads bills, receipts and spend exports you drag in, connects to your systems and keeps the source on every number, then produces SECR summaries and framework reports from the same inventory, with expert support from Ella's team.

    How to get ready for UK ESG reporting: a 6-step plan

    Use this plan for the next reporting cycle. Each step has an owner and an output so it can go into a project plan.
    How to get ready for UK ESG reporting: a 6-step plan
    StepWhat to doOwnerOutput
    1. Map entitiesList every UK and EU entity with employees, turnover and balance sheet for the last two yearsFinanceEntity register
    2. Map requirementsApply the thresholds in this guide to each entity and the groupSustainability lead with legalRequirement map by entity and year
    3. Set boundariesDecide the organisational boundary and base year for energy and emissionsSustainability leadBoundary note
    4. Name data ownersAssign an owner for each site, fleet, utility account and spend categorySustainability leadData owner list
    5. Collect with evidenceCollect 12 months of activity data with a source for each figureData owners, tracked centrallyEvidence-backed inventory
    6. Report and reuseProduce SECR, ESOS, climate disclosures and questionnaire answers from one data setSustainability leadReports with an audit trail

    How Ella helps

    ESG reporting software

    Collect ESG data once and produce SECR, climate disclosures and questionnaire answers from the same evidence-backed data set.

    Carbon accounting software

    Set boundaries, build your Scope 1 to 3 inventory and generate an SECR summary with a source on every number.

    ESG strategy software

    Turn your requirement map into targets, reduction plans and a roadmap your board can follow.

    Related resources

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    SECR Reporting Explained: Who Must Report and What to Include

    SECR (Streamlined Energy and Carbon Reporting) requires UK quoted companies, and large unquoted companies and LLPs, to report their energy use and greenhouse gas emissions in their annual report. A company is large if it meets two of three tests: turnover of £36m or more, balance sheet of £18m or more, or 250 or more employees. Scope 3 is optional.

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    ESOS explained: who qualifies for ESOS Phase 4 and how to comply

    ESOS, the Energy Savings Opportunity Scheme, is a mandatory UK energy assessment for large undertakings and their corporate groups. You qualify for Phase 4 if any UK group member has 250 or more employees, or turnover above £44 million and a balance sheet above £38 million, on 31 December 2026. Notify compliance by 5 December 2027.

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    IFRS S2 explained: ISSB climate disclosure requirements, reliefs and the 2027 amendments

    IFRS S2 is the ISSB's climate disclosure standard, issued in June 2023 for reporting periods from 1 January 2024 wherever it is adopted. It builds on the four TCFD pillars and adds Scope 1, 2 and 3 emissions, industry metrics, transition plans and scenario analysis. In the UK it applies through UK SRS S2.

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    CSRD after the Omnibus: who is in scope, the new thresholds and the reporting timeline

    After the Omnibus I Directive, CSRD applies only to EU companies with more than 1,000 employees and over EUR 450 million net turnover, plus non-EU groups with EUR 450 million EU turnover. Most newly in-scope companies report on financial years starting in 2027, using simplified ESRS, with limited assurance only.

    Frequently Asked Questions

    What are the ESG reporting requirements for UK companies?

    The main mandatory UK ESG reporting requirements are SECR for quoted and large companies, Companies Act climate-related financial disclosures for companies with more than 500 employees and £500m turnover, UK SRS for listed companies from 2027, ESOS Phase 4, modern slavery statements, gender pay gap reporting and PPN 006 for large government contracts.

    Is ESG reporting mandatory in the UK?

    Parts of it are. There is no single ESG reporting law, but SECR, climate-related financial disclosures, ESOS, modern slavery statements and gender pay gap reporting are all mandatory for companies above their thresholds. UK SRS is mandatory on a comply or explain basis for listed companies from 2027 and voluntary for others.

    Which companies have to do SECR reporting?

    All quoted companies, plus large unquoted companies and LLPs that meet two of three tests: 250 or more employees, turnover of £36m or more, or a balance sheet of £18m or more. These SECR thresholds did not change when the Companies Act size thresholds rose in April 2025.

    When does UK SRS become mandatory?

    For companies with listed shares, the FCA's rules apply to accounting periods starting on or after 1 January 2027 on a comply or explain basis, with first reports in 2028. There is one year of relief for Scope 3 and two years for wider UK SRS S1 disclosures. For other companies UK SRS is voluntary for now.

    Does CSRD apply to UK companies?

    Only through EU activity. EU subsidiaries of UK groups with more than 1,000 employees and over €450m turnover report from financial year 2027. A UK parent reports from financial year 2028 if the group has more than €450m of EU turnover and an EU subsidiary or branch above €200m.

    What is the threshold for a modern slavery statement in the UK?

    A commercial organisation that supplies goods or services, carries on business in the UK and has annual turnover of £36m or more must publish a modern slavery statement for each financial year.

    Do private companies have to report on climate in the UK?

    Yes, if they have more than 500 employees and turnover above £500m. They must make Companies Act climate-related financial disclosures in the strategic report. Smaller large private companies still report energy and carbon under SECR.

    Is UK ESG reporting going to change?

    Very likely. The Modernising Corporate Reporting consultation closes on 30 November 2026 with an outcome due by the end of May 2027, DESNZ plans to consult on SECR and ESOS, and the Companies Act climate disclosure review is due by spring 2027.

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