Head of Marketing
Edited: 23 Dec 2025
10 min read
If your business has over 250 employees and a turnover of £36 million or more, the answer is yes. You are legally required to disclose aspects of your company’s carbon emissions.
Navigating climate-related reporting is increasingly important for UK businesses, both to ensure compliance and to meet growing expectations around transparency. Frameworks such as SECR, TCFD-aligned disclosures, CRFD, ESOS and UK Sustainability Reporting Standards (UK SRS) each play a role in shaping how organisations report on climate and sustainability.
Understanding how these frameworks apply can help businesses meet legal requirements, improve energy efficiency, manage climate-related risks, build stakeholder trust and support wider decarbonisation efforts.
Ensuring compliance and strategic advantage
Understanding the evolving regulatory landscape
The UK policy landscape for climate disclosure continues to evolve as the government strengthens its commitment to addressing climate change and achieving net zero.
Over recent years, new and expanded reporting requirements have been introduced to improve transparency and accountability around environmental impact. For many organisations, climate disclosure is no longer just a compliance exercise, but a strategic consideration that affects procurement, investment and reputation.
The importance of climate disclosure frameworks
For UK companies, understanding climate disclosure frameworks is essential. The introduction of Streamlined Energy and Carbon Reporting (SECR) in 2019 marked a significant shift by requiring large companies to disclose energy use and carbon emissions.
Since then, expectations have expanded. TCFD-aligned reporting has become mandatory for many large companies and financial institutions, embedding climate risk and opportunity into mainstream financial reporting. These disclosures now also underpin newer sustainability standards being developed internationally and in the UK.
Streamlined Energy and Carbon Reporting (SECR)
What is SECR?
SECR is a UK government initiative designed to improve energy efficiency and reduce carbon emissions. It requires qualifying organisations to report on energy use, greenhouse gas emissions and energy efficiency actions.
Who needs to comply?
SECR applies to large UK companies and limited liability partnerships that meet at least two of the following criteria:
turnover of £36 million or more
balance sheet total of £18 million or more
250 or more employees
What needs reporting?
Companies must disclose:
total energy use, including electricity, gas and transport fuels
Scope 1 and Scope 2 greenhouse gas emissions
energy efficiency actions taken during the reporting year
a narrative description of methodologies used
Where, when and how to report?
SECR information must be included in the directors’ report within annual financial filings and reported annually in line with the financial reporting cycle.
For more detailed information, refer to the UK Government’s Guidance on SECR.
Task Force on Climate-related Financial Disclosures (TCFD)
What is TCFD?
TCFD provides a framework for reporting climate-related financial risks and opportunities in a consistent and comparable way.
Who needs to comply?
TCFD-aligned disclosures have been mandatory in the UK since April 2022 for many large companies, publicly listed companies and financial institutions.
What needs reporting?
Disclosures are structured around four pillars:
governance
strategy
risk management
metrics and targets
Where, when and how to report?
TCFD-aligned disclosures are typically included within annual financial filings and reported annually. In the UK, these disclosures now form the foundation for the UK Sustainability Reporting Standards, which align with international standards developed by the International Sustainability Standards Board.
For more details, refer to the UK Government’s TCFD-Aligned Disclosure Application Guidance.
Climate-related Financial Disclosure (CRFD)
What is CRFD?
CRFD refers to the UK’s non-financial and sustainability reporting requirements that enhance transparency around environmental, social and governance impacts.
Who needs to comply?
CRFD applies to large companies and certain public interest entities that meet size thresholds, including turnover, balance sheet total and employee numbers.
What needs reporting?
Disclosures typically cover:
environmental impacts, including emissions and resource use
social and employee matters
governance practices
human rights
anti-corruption and bribery measures
Where, when and how to report?
CRFD information is included in the non-financial statement within the annual report and is reported annually.
For detailed and specific guidance, refer to the UK government’s documentation on climate-related financial disclosures, accessible here.
Energy Savings Opportunity Scheme (ESOS)
What is ESOS?
ESOS is a mandatory energy assessment scheme aimed at improving energy efficiency in large organisations.
Who needs to comply?
ESOS applies to large UK undertakings and corporate groups, including those with:
250 or more employees, or
turnover above £44 million and a balance sheet total above £38 million
What needs reporting?
Organisations must:
measure total energy consumption
carry out energy audits covering at least 90 percent of energy use
maintain a compliance evidence pack
Where, when and how to report?
ESOS operates in four-year compliance phases. Organisations must submit a notification of compliance to the Environment Agency and retain evidence internally.
For further details, please refer to the official ESOS guidance.
UK Sustainability Reporting Standards (UK SRS)
What are UK SRS?
UK SRS are sustainability reporting standards being developed to provide consistent, decision-useful ESG information, aligned with global standards set by the ISSB.
Who needs to comply?
UK SRS are not yet mandatory, but adoption is increasing among large and publicly traded companies. The UK government has signalled that these standards may become mandatory in the future.
What needs reporting?
UK SRS cover:
environmental metrics, including greenhouse gas emissions
social factors such as labour practices and human rights
governance, risk management and controls
Where, when and how to report?
Disclosures may be included in annual reports or published separately, typically on an annual basis.
For more details, visit the UK Government’s Guidance on UK Sustainability Reporting Standards.
An overview of climate disclosure requirements for UK businesses
Climate Disclosure | SECR | TCFD | CRFD | ESOS | UK SRS |
|---|---|---|---|---|---|
Legal requirement? | Yes | Becoming mandatory in the UK | Yes (part of NFRD) | Yes | No, but increasingly adopted |
Who needs to comply? | Large companies and LLPs in the UK | Large companies, financial institutions, publicly listed companies | Large companies and public interest entities in the UK | Large UK undertakings and corporate groups | Voluntary - Large and publicly traded companies |
Specific criteria includes | Over 250 employees. Turnover of £36m+ | Over 500 employees. Turnover £500m+ | Over 500 employees. Turnover £500m+ | Over 250 employees. Turnover of £44m+ | Voluntary - Not specified |
What to report? | Energy use, GHG emissions, energy efficiency actions | Governance, strategy, risk management, metrics & targets | Environmental, social, governance impacts, human rights, anti-corruption | Energy consumption, energy audits, compliance evidence pack | Environmental, social, governance metrics |
Where to report? | Annual financial filings | Annual financial filings | Annual reports | Environment Agency online portal | Annual or sustainability reports |
When to report? | Annually, since 2019 | Annually, from April 2022 | Annually, since 2017 | Every four years, next in Dec 2023 | Annually, voluntary |
Conclusion
Navigating climate-related reporting is essential for UK businesses. SECR, TCFD-aligned disclosures, CRFD, ESOS and UK SRS each contribute to improving transparency, managing climate-related risks and supporting decarbonisation.
Understanding how these frameworks apply helps businesses meet legal requirements, unlock strategic benefits and build trust with stakeholders.
Ready to take climate action?
Our team of experts can help your business understand and respond to climate disclosure requirements in the UK. If this article has inspired you to take the next step, speak to our team today.